Scottish Government

Chapter Four: Comments on Spatial Policies and Locational Considerations

Introduction

4.1 Paragraphs 16-38 in the Draft SPP set out the proposed national guidance on the criteria to be taken into account by planning authorities in updating their development plans; with the aim of identifying areas likely to be suitable for locating onshore wind farms, and those areas which would not be suitable for such developments. Paragraphs 36-38 in the Draft SPP covered locational considerations in respect of biomass and other technologies. Comments were received on the general approach and on the individual criteria themselves.

4.2 Paragraphs 39-43 in the draft guidance covered the approach which local planning authorities would be required to take to assess the capacity of their areas to accommodate renewable energy developments. This proved to be quite a contentious proposal and comments received on this aspect are set out in paragraphs 4.55-4.66 below.

General Comments

4.3 Of the 51 respondents to paragraphs 16-19, 11 expressly supported the approach set out in the Draft SPP, the balance were not necessarily all opposed to it, although earlier concerns expressed regarding the "broad areas of search" ( BAS) methodology and need for a more prominent national perspective, were also repeated here.

4.4 Several respondents made the point that the SPP should highlight the main planning and environmental constraints that could affect all technologies, not just wind farms. In this context respondents asked for more specific guidance on small-scale wind developments, biomass, hydro schemes and their effect on fish stocks.

4.5 A number of comments were made about the BAS approach. There were views that it may be too late, as many projects and certainly most of the large ones were already in the planning system. Five respondents expressly opposed the BAS as against a criteria-based policy approach. Several respondents were keen to stress that the BAS approach should not preclude wind farm proposals in other areas, while one respondent was concerned that the guidance would allow wind farm developers to build turbines wherever they liked. There was a view that the SPP6 should indicate that Scottish Ministers will respect those areas where it has been determined that wind farm development should be avoided.

4.6 Some concerns were again expressed about the potential "opt out" from the BAS approach indicated by paragraph 18. In this context, there was a request for further guidance on the definition of "limited potential".

4.7 There was a view that the SPP should set out detailed criteria for assessing individual development proposals. One respondent suggested that the criteria in paragraphs 20 to 35 were also relevant to considering planning applications, as well as defining BAS, and that the role of these paragraphs for that purpose should therefore be clarified.

Locational Considerations

Natural Heritage

4.8 There was a relatively high rate of response to this section with 68 respondents (29% of all respondents) offering comment, 19 (28%) actively expressing support for the approach taken while 31 (46%) either disagreed with it or felt that the recommended approach did not go far enough. Opposition to the approach was particularly concentrated amongst voluntary sector and individual public respondents (see Table 4.1 below).

Table 4.1: General Views on Natural Heritage Locational Criteria

4.9 There was a significant body of responses which expressed concern that the guidance appeared to downgrade the protection afforded to sites which were not of international or national importance. Twenty one respondents (31%) were concerned that the guidance did not attach sufficient importance to AGLV or Regional Park designations. There were a number of suggestions regarding potential additional areas for protection from wind farm developments and these included: designated gardens and landscapes; important biodiversity resources (although one respondent felt that the Scottish Biodiversity List was ill suited to that purpose); areas of blanket bog and the Central Scotland Forest were also mentioned. Some thought that locations valued by the local community should also be identified as concerns about sense of place and identity were not adequately covered. There was a view that Annex A should include World Heritage Areas.

4.10 There was a view that the landscape assessment methodology endorsed by NPPG 6 and PAN 45 should be continued. There were concerns that if the zoning system used by SNH sets out the agreed national policy position, this should be reflected in the guidance. One respondent was disappointed that the SNH Strategic Locational Guidance on Onshore Wind-farms was not explicitly mentioned. Regarding the cross reference to NPPG14, one respondent noted that this does not properly reflect the wording of the legislation surrounding Natura sites. There were other views that the SPP might recommend that Councils carry out their own local landscape assessments for wind farms as they would be in the best place to make judgements about the level of protection to be given to locally designated sites.

4.11 One planning authority, which currently applies buffer zones around a National Scenic Area following guidance from SNH, suggested that it was reasonable to continue to pay attention to the visual impacts in such circumstances. Another respondent indicated that, given the long distance visibility of some plant, it may be appropriate to adjust boundaries of zones of protection around areas designated for their landscape value. Others felt that local authorities should be allowed the discretion to protect appropriate areas on the perimeter of nationally designated landscapes. There was a suggestion that there should be 4-8 mile buffer zones around National Parks, NSAs and natural heritage sites within which giant turbines would not be permitted. One respondent suggested that buffer zones would exist in practice if not in name.

4.12 A cluster of respondents thought that phrases in the draft guidance potentially weakened the protection afforded to the landscape and sought clarification of the terms "satisfactorily mitigated" and "unreasonable restrictions". A number of respondents sought express reference to the Sandford Principle, which gave precedence to conservation interests when these came into conflict with other objectives.

4.13 A small minority of respondents felt that too much weight was being given to landscape matters. There was a view that the SPP needed to recognise that wind farms will impact on the landscape, but the temporary nature of the structures means that a significant level of impact can be accepted. It was also suggested that there would be merit in including a reference to the environmental enhancement opportunities presented by some proposals and encouragement for developers to consider these when submitting applications

Historic Environment

4.14 There were few responses to this section (13) and most of those offered a general welcome for its content. One respondent asked for an explicit statement that planning authorities should seek to meet contribution targets away from areas where development would conflict with the policies of NPPG 5 and NPPG 18, if it was likely that impacts could not be satisfactorily mitigated, while another was concerned that unnecessary protection was being afforded to Scheduled Ancient Monuments in terms of landscape setting, pointing out that land cover and land use in the vicinity of a monument would be likely to have changed considerably from the historic position. However, another view was that Local Sites and Monuments Records should be taken into account in identifying search areas.

Green Belts

4.15 There were relatively few (20) responses to this section, of which 9 were wholly or generally supportive (including all of the voluntary groups who responded). Two criticized the guidance for being highly restrictive. The most frequent comments related to what might, or might not, constitute "appropriate exceptions". One local authority suggested that for SPP 6 to conform to SPP 21, paragraph 32 should include a sentence requiring the need for planning authorities to identify any exceptions in their development plans. Another sought clearer guidance, as suitable sites for wind farms in its area, and in many other conurbations, would almost certainly be on Green Belt land. Others suggested a need for more cross referencing between SPP 6 and SPP 21.

4.16 One respondent argued that wind developments allow land to remain open and available for its previous use and rejected any requirement for alternative sites to be investigated before any development in Green Belts.

Tourism and Recreational Interests

4.17 There was a relatively large number (63) of responses to this section, of which 10 were wholly or generally supportive of the stance in the draft SPP (see Table 4.2 below). 57% of the responses disagreed with the SPP approach and many of these expressed concerns regarding the need for greater protection of Regional Parks, (eleven of the eighteen private individuals who responded raised this as an issue). There were other objections to the equivocal stance of the guidance on the impact of wind farms on tourism; from both promoters and objectors to wind farm developments.

Table 4.2: General Views on Tourism/ Recreational Locational Criteria

4.18 One strand of opinion reflected in the responses was that there were already clear negative effects from current wind farm developments. Views from this group included the assertion that recent surveys gave conclusive evidence of the negative effect of multi-turbine wind farms on attracting tourists. These respondents felt that it was important that Scotland did not become identified with wind farm blighted landscapes as this would have important implications for the local and wider Scottish economy. Consequently, developers should be actively discouraged from proposing turbines in areas where tourism supports many local businesses. In this context, it was suggested, a distinction should be made between Scottish rural tourism, where landscape quality forms the heart of the tourism product and other forms of tourism. There was also a view that many key tourist attractions were outwith statutorily protected areas and it was therefore vital that local authorities were provided with guidance about where local economic activity was significantly influenced by tourism.

4.19 Another body of opinion, mainly from energy businesses, expressed concerns about continued research into the effects of wind farms on tourism. These respondents advanced views which included the statement that the section ignores work done to date and defers guidance to a document that had neither been completed or peer reviewed. There were several comments that the SPP should only refer to evidence- based and peer reviewed information and a plea that the commissioned research referred to in the SPP should be published as a matter of urgency, with full consultation on any resulting changes to the policy. One respondent felt that effects on tourism were complex, multi-layered and that the comments outlined in the draft SPP were reflective of the fact that renewable energy developments had had no discernable detrimental effects on tourism so far.

4.20 A smaller group of respondents felt it was misleading to imply that current research would provide the answer. They suggested that it is difficult to predict the long term response of tourists and those seeking to enjoy outdoor recreation. There was a view that the precautionary principle should apply until the position is clarified.

4.21 It was pointed out that despite its title the section dealt almost exclusively with tourism. In this context, it was felt that there was a significant oversight in the guidance since it ignores hill ranges as a recreational resource, particularly in Central Scotland. It was considered that the SPP should refer to the strategic importance for outdoor recreation of regional and forest parks and long distance routes.

Aviation and Defence Interests

4.22 There was only a small number (16) of respondents to these paragraphs, half of whom (8) expressly support the approach, while most of the others sought some clarification or additions. Three respondents sought further detail of the consultation procedure, with one concerned that it would place an unacceptable burden on developers and give MoD more power to oppose schemes than in the rest of the UK. Another respondent suggested that such matters would be best resolved between the developer and interested parties. A business respondent highlighted cumulative impact on airspace as an issue that required to be considered and another was concerned about serious potential effects on Prestwick Airport. One Council wanted clarification of the reference to "insurmountable" concerns, as they felt safety should not under any circumstances be compromised.

Communities

4.23 The second largest number of responses (118 - 51% of all those responding) to the consultation document was received in relation to this section and the associated consultation question (see Table 4.3 for details). The position set out in the draft SPP in relation to separation distances and definition of a large wind farm were not generally supported by respondents as a whole (there was only 6% support on the first issue and 25% on the second). Voluntary and public respondents were particularly opposed to the SPP position (that the proposal gave insufficient protection) but business respondents also disagreed, although for different reasons, (that it would be too restrictive).

Table 4.3: General Views on Communities Locational Criteria

4.24 The majority who were concerned about the proposed separation distance mentioned the fact that there was no explanation as to why 1.5km was chosen, it appeared to be completely arbitrary and impacts could be significant over a wider distance depending on local topography and other variables. Some felt that 1.5km could be sufficient in terms of noise impact but if there was no natural screening or the development was particularly large, landscape issues may dictate a wider buffer zone. There were many suggested alternative distances ranging from six to twenty times the turbine blade tip height and between 400m to 10km. The most frequently mentioned alternatives were between 2km and 3 km.

4.25 A significant cluster of responses were concerned that no appropriate separation distance was given in the document for individual houses, nor that there was any definition of what constituted a "community". There was a view that the guidance should also consider places where large numbers of people congregate such as visitor centres and similar tourist and recreational attractions. There were also questions about how the separation distance should be measured - would it be measured from a wind farm site boundary or from the closest turbine and would it be measured to settlement boundaries or the nearest noise sensitive property?

4.26 There were other views that there should be more flexibility in the chosen approach, national standards were inappropriate and the use of policies that identified when an impact was unacceptable would be more appropriate than a separation distance 'per se'. There were suggestions that required separation distances could best be assessed through an EIA which would cover all of the different impacts in detail. One respondent wanted a scientifically calculated safe distance to be established on a case by case basis. There was also a concern that any thresholds should not be interpreted in a way that would apply to small community owned wind farm projects.

4.27 In relation to the definition of "large scale wind farms", a number of respondents indicated that there was no explanation of why the 20 MW limit was chosen. There were several references to the Electricity Act Section 36 threshold of 50 MW which was thought by some to be more appropriate. Other suggestions put forward ranged from 5 MW to 100 MW, to all "commercial" wind farms. There was a view that if 20 MW was the only practical definition, then it should be kept under regular review.

4.28 A cluster of responses suggested a different approach with wind farm scale defined by the number of turbines and/or hub height. On this approach, it was considered that the definition of "commercial scale" should be turbines with a hub height in excess of 15m as in the relevant EIA Regulations. A number of respondents also wanted guidance to be given on all potential sizes of wind farm (local, major, national) reflecting the Planning White Paper's hierarchy for applications.

Cumulative Impact

4.29 There was also a reasonably large response (52 respondents - 22% of the total) to this section of the SPP. Nearly a quarter of these made broadly supportive comments, only 12% expressed clear opposition, but the greatest proportion (nearly two thirds of those commenting on paragraphs 29-31) had questions about the definition and measurement of the suggested approach (see Table 4.4).

4.30 A group of respondents indicated that cumulative impact needed to be better defined. There were comments from this group that the distinction between simultaneous and sequential impact was not always clear. Many respondents agreed that cumulative impact was more than simply a summation of visual impact and suggested that SPP6 should address cumulative impacts for additional criteria including: species habitats, archaeology and noise, together with clearer guidance on how these were to be considered and weighted. There was a view that assessment should have regard to the inter-visibility with other intrusive land uses such as mineral working sites. One respondent suggested that the term "shortly" should be removed from paragraph 29, as this would depend upon the nature of the route and the mode of travel. There were other views that locations or features treasured by the community, and which contribute to its identity, should be highlighted in any assessment of cumulative impact. Another respondent suggested that the draft SPP should highlight the need for further independent academic research to consider the long term effects on ecology resulting from cumulative habitat loss and more specific impacts on a particular species.

Table 4.4: General Views on Cumulative Impact Locational Criteria

4.31 There was feeling amongst some respondents that SNH guidance was appropriate but concerns that it did not have the same status as the SPP. There were calls for more detailed guidance on the issue, definition of "unacceptable cumulative impacts" and inclusion of the full title of the SNH guidance to which the SPP referred. Another respondent sought clarification of the Scottish Executive's view of the SNH guidance on wind farm development outwith designated sites, while concerns were expressed that the SPP did not provide guidance on how to assess the impacts on the "wild qualities" of land that may cross over National Park boundaries and which were important for creating the setting of the National Park.

4.32 However, there were also some views that the SNH guidance was not of a format that was suitable to be recommended for use in an SPP and that it had never been peer reviewed through public consultation. Some respondents suggested that the more sophisticated techniques for the assessment of cumulative impacts, which are carried out in Environmental Impact Assessments, should be detailed and set out in the SPP itself. Others felt that the detailed survey and modelling of an EIA could produce a much more accurate picture and many good sites may be lost if the SNH assessment procedure was applied too rigidly.

4.33 A number of respondents made procedural points. One indicated that SNH advice indicated that there was a role for strategic planning in assessing cumulative impact and developing appropriate policies and the SPP should recognise this. It was also suggested that Local Planning Authorities should take into account the views of neighbouring authorities when undertaking assessments of cumulative impact. There was a view that the SPP should include a specific requirement that local authorities work closely with SNH in defining areas, where, due to cumulative impact with existing wind farms, further development would not be allowed.

4.34 There was a view that in the vast majority of cases, planning authorities were unlikely to have a sufficiently detailed level of information that would allow the justified preclusion of all future wind farm developments in a particular area and this part of paragraph 31 should be deleted as it runs contrary to the principle of treating each planning application on its merits.

4.35 A number of energy businesses pointed out that the BAS approach would be likely to give rise to a larger concentration of wind farm developments in given areas, which would naturally give rise to greater cumulative effects. They suggested that therefore, there needed to be a higher level of tolerance of the greater cumulative effects arising within BAS areas.

4.36 Other points made in relation to this section included:

• hydro schemes can have significant cumulative impacts on fisheries and SPP6 should provide guidance on this matter ( NDPB)
• it would be possible to minimise the cumulative impact of wind farms by combining them into fewer large wind farms (Community Council)
• no new wind farms should be constructed within 15 miles of any wind farm of more than 40 turbines (Public)
• this section should also apply to decisions on proposed wind farm extensions (Local Voluntary Body)
• the significant landscape work required of local authorities as part of cumulative impact assessments will have significant resource implications (Local Authority)

Wind Resource

4.37 There was only a relatively small group of comments (from 20 respondents) relating to this locational guidance factor. In general the approach set out in the SPP was broadly supported, the main outright opposition coming from a small majority of energy businesses, who thought it was inappropriate.

4.38 One local authority suggested that wind resource should be considered in the first instance at national level as this would avoid duplication of effort between local authorities and the revisiting of these issues in every inquiry and appeal. However local assessments were expressly supported by 2 other respondents.

4.39 The implications of the approach for Local Planning Authority resources (expertise and cost) were raised by 4 respondents. Two respondents pointed to difficulties in assessing ground stability at a strategic level and asked whether planning authorities were properly resourced to undertake this work. Access issues were also mentioned in this context.

4.40 A number of points were raised about consultations. A group of respondents welcomed reference to consultation with the energy development industry. They suggested that this would ensure development in BAS would be possible in an economic sense. Two respondents wanted the SPP to require developers to make their wind and electricity generation data available to the public and one suggested that developers should be consulted regarding wind speed. A further respondent felt that it was important that consultation with key agencies (such as SEPA and SNH) should be stressed.

4.41 Respondents who were critical of the BAS approach made various comments including the suggestion that wind resource assessment data fails to identify localised opportunities, as the accuracy and precision of the data is not appropriate to site specific assessment. One respondent suggested that by definition an area of search is not precisely quantifiable and that if planning authorities were in a position to do as requested they would be in a position to suggest specific sites. One noted that detailed monitoring or technological change may allow sites perceived to have a lower wind resource to prove economically viable and another suggested that resource assessments are not a necessary aspect of identifying BAS. A view was expressed that wind resource and commercial viability were for the developer alone to consider.

4.42 Other points made in relation to this section included:

• a respondent suggested that this section reflected standard practice and that it was the lack of adequate advice at national level which was the problem (National Voluntary Body)
• one respondent wanted to see overlay maps produced by planning authorities in order to identify suitable areas for all types of renewable energy development as well as for areas of exclusion (Local Voluntary Body)
• one respondent suggested that BAS would include far more capacity than required such that it was not necessary to accelerate their development (National Voluntary Body)
• one respondent (Energy Business) suggested economic viability was not a matter for councils, while another (Planning Consultant) wanted economic viability criteria explicitly identified in the SPP

Electricity Grid

4.43 There was a relatively high level of interest in this section with a total of 48 responses received. There was a considerable level of concern about the approach being advocated in the SPP with respect to this factor and only four responses (8%) were of a broadly positive nature (see Table 4.5 for details). Responses tended to fall into two broad camps. One felt that grid capacity was important and sought clarification of how it could best be taken into account. The other took the view that it should not be a major determining factor in defining BAS.

4.44 Most of those in the first group felt that a more strategic approach to this issue was required with capacity and targets developed in the first instance as part of a national strategy, possibly via links to the National Planning Framework. It was felt that this would provide the necessary clarification of the geographic distribution of grid capacity which could then be made available to Councils to enable them to consider how their areas could contribute to national targets on a more informed basis. There was also a view that consideration should be given, in consultation with transmission owners, to strategic selection of search sites where clusters of generation could be located using a common asset, but which may not yet be identified in either planning or grid upgrade plans. Further clarification was also sought to ensure planning authorities do not preclude developments that do not require to be accommodated within existing and planned grid upgrades.

Table 4.5: General Views on Electricity Grid Locational Criteria

4.45 One NDPB respondent set out their detailed view of the appropriate process to take account of the uncertainty caused by future unknown grid upgrades. This was that,

"We recommend that in identifying broad areas of search for onshore wind farms, and in identifying a local renewables contribution, planning authorities should do so in two categories. Firstly they should identify BAS and local contributions based on existing and planned grid capacity and the SEA of that plan should take account of the new environmental impact associated with the planned grid capacity. Secondly, they should identify any further local contributions and additional areas of search which would be made possible as a result of further grid upgrades….. The SEA of this further plan should take into account the new environmental impacts associated with the new grid upgrades. Identification of further renewables potential in this second category provides a mechanism whereby further enhancement of the grid, beyond that which is currently planned, can respond to the identification of the most suitable areas for renewables development, rather than (as at present) respond reactively to development pressures. If these two categories of local contribution and broad areas of search for onshore windfarms are established - based on 'existing' and 'new' grid capacity respectively - it should be evident that, all other factors being equal, a renewables proposal in the first category should be preferred to one in the second, on the basis that it avoids the cost and impacts associated with new grid infrastructure. However, it should be open to a planning authority to argue that development proposals or indeed broad areas of search within the second category should be preferred to proposals or areas of search within the first category, in situations where that can be justified on the basis of lower environmental or other sensitivities or particular economic benefits."

4.46 The alternative view by a group of respondents was that the process was being too "grid led". On this view, grid capacity should follow, and thus enable, the exploitation of recognised wind resources and hence areas of search should not be limited to currently available or planned grid capacity. Respondents contended that further upgrades to the grid will be essential if potential is to be realised and that the guidance should reflect this. In this context, it was asserted that current upgrades are all in response to development proposals and there has been a suggestion in the electricity industry that grid connections were only given to projects that have been granted planning permission; risking a Catch-22 situation where projects would not be given planning permission because they do not have a grid connection and would not be given a grid connection because they do not have planning permission, thus stalling progress.

4.47 One respondent thought grid connection should not be taken into account in determining applications and others thought that planning should not take the issue into account at all, as it was for developers to make a judgement and take the risk on whether a grid connection would be possible. There was also a view that, theoretically, grid capacity could be supplied anywhere in the UK so a grid connection was not technically a planning constraint.

4.48 Other points made in relation to this section included:

• the Executive should seek detailed advice on the grid challenges due to erratic and unpredictable generation via wind power (Local Voluntary Body)
• there is a need to clarify the timescale for completing the commissioned study into renewable generation and the electricity grid ( NDPB)
• more consideration should be given to local applications (such as heat schemes) which do not depend upon grid capacity (Local Authority)
• what restrictions, if any, will be placed on indiscriminate and widespread expansion of above ground transmission? ( NDPB) The SEDD should commission research into improving the technologies for undergrounding transmission lines (National Voluntary Body)
• planning permission should not be given to a project which cannot be executed (Public)
• there is a need to impress on infrastructure operators the importance of engagement in the development plan process (Local Authority)

Biomass

4.49 Almost every response to this section (31 in total) displayed a favourable attitude towards biomass energy, although about half still had various queries and suggestions for improvement to the document (see table 4.6). One general theme, repeated by a number of respondents (8), was the desire to see more detailed guidance on planning for biomass.

Table 4.6: General Views on Biomass

4.50 Those responding to this section tended to the view that the guidance should place a greater emphasis on the use of biomass and CHP, with an indication of the suitability of residential and employment area locations. One respondent pointed to the potential role of the National Planning Framework and another suggested that in considering opportunities, local planning authorities should include the identification of small, medium and large scale projects.

4.51 Suggestions for additional guidance on this topic included the encouragement of large scale transportation of biomass feedstock onto railway and waterway networks. There was also a suggestion that planning guidance for biomass should align with Indicative Forestry Strategies and give preference to Forest Stewardship Council certified sources and a further request that the guidance should support a hierarchy of biomass priorities. One respondent noted the omission of references to waste biomass as a renewable resource and sought guidance on locational and other issues surrounding energy from waste, noting that this was particularly important if CHP was to be realised. One respondent argued that biomass raised grid issues and that relevant industry consultation is essential. Another felt that the focus on electricity rather than heat or bio fuels ignored a large area of potential.

4.52 Other suggestions included re-titling the section to "bio-fuel" and adding a cross reference to SPP10. There was a request for recognition of the support that biomass production can bring to vulnerable rural local economies and that significant weight should be given to this factor in planning decisions. One respondent emphasised that locating biomass plants away from the fuel source reduced the associated environmental benefits.

4.53 There was a suggestion that the final SPP should recognise possible significant landscape implications of planting energy crops. One respondent noted that technical information exists which could be used to inform regulation in Scotland so that environmental standards for biomass fuelled systems could be rapidly developed. One respondent questioned whether adverse smoke impact had been considered?

Other Technologies

4.54 Of the 23 responses to this section, several respondents (5) explicitly ask for more guidance and some were concerned about undue focus throughout the SPP towards on-shore wind. One respondent questioned what technologies are to be considered here and suggested a need to refer to PAN 45 more clearly. There was a group of responses seeking more emphasis on other sources of energy such as energy from waste (3), landfill gas, hydropower (2), passive solar, wave and tidal energy and suggested more of an emphasis on heat generation.

4.55 Detailed suggestions included the addition of cross references to SPP 10 and PAN 63 and that PAN 45 should be kept under regular review. Several respondents (5) asked for guidance on planning for the ancillary infrastructure required to facilitate off-shore energy developments ( e.g. grid infrastructure, near-shore control buildings and mooring points).

Local Contributions

4.56 This section of the draft SPP attracted a considerable number of responses (67), reflecting the fact that it set out a key, and what proved to be a controversial component of the suggested guidance. Only 8 responses (12%) were broadly or wholly supportive, while the remainder had varying degrees of concern with the approach being advocated. Within this latter group were those who sought to change the process to make it work more effectively (on balance the majority) and those who felt that it could and for some, should not, be made to work. See Table 4.7 for a more detailed breakdown of responses.

4.57 There was a strong body of opinion, led by local authorities but including other respondent groups, which argued that a "top down" approach, with a clear national overview (perhaps provided by the National Planning Framework 2) was the only realistic way to proceed with the assessment of local contributions. One Local Authority set out a suggested methodology for this, which was that,

"….the Scottish Executive should collect information from planning authorities on: • broad areas of search for wind farms, if already done; • all local natural heritage designations (in GIS format preferably) (the Executive should have access to national and international designations already); • all built and cultural heritage sites (in GIS format preferably); • all suitable sites for other commercial renewable energy technologies identified in the development plan; and • any marine energy proposals in the planning process, or at the scoping Stage. The Executive should then set out the local contribution/targets for each local authority and/or city region in the National Planning Framework."

4.58 There were also views that indicative regional figures should be established which could be apportioned by agreement between groups of planning authorities. In particular, it was considered that there was no clear case for the Executive to devolve the issue of assessing grid capacity - a purely technical exercise which should yield a map of locations where connections/inputs up to a certain level could be accommodated. This information could be made available to local authorities to enable them to determine what contribution their areas' could make to optimising the use of transmission capacity.

Table 4.7: General Views on Local Contributions

4.59 Without such an approach, there were queries regarding how it could be guaranteed that all the local contributions would sum to the national total. There were views that a mechanism for calculating local contributions would have to be established and "local" defined (local authority, development plan area, settlement or other)? It was queried whether local authorities should be setting a range of short, medium and long term goals with targets, timeframes, performance indicators and monitoring/ reporting for each renewable energy sector? It was felt that local contributions would be likely to be complex and potentially contentious and that duplication of the exercise across the country would be inconsistent with best value. One respondent felt it was particularly inappropriate for authorities in conurbations to each develop their own separate search areas. Some felt that the proposal may be open to abuse by authorities and that SPP6 did not explain how the government would respond where an authority set an unrealistically low target or what "balancing mechanisms" might be adopted for over-enthusiastic authorities?

4.60 A number of respondents pointed out that the process would be time consuming and felt that it was essential that projects were not held back and further delays introduced, given the impact this would have on market confidence. It was suggested that the Executive should consider how it could support local authorities to simplify this process and ensure that it was completed quickly. Several respondents pointed out that the approach would require specialist expertise which would have resource issues for Councils, which the guidance does not address. It was suggested that there was a possible role for the Planning Development Programme in this context. Another view was that Planning Authorities must be encouraged to work together in drawing up their assessments in order to make the best use of available expertise.

4.61 There was a view that the suggestion that planning authorities should consider the potential for offshore renewables, when the SPP does not attempt to deal with this issue itself, was unacceptable without further clarification. Other respondents considered that the effect which the growing contribution from marine technologies will have on the expected contribution from on-shore technologies should be an important factor in how authorities plan for the short and medium term. There was a view that offshore development should also be plan-led to avoid difficulties that it was considered had been created by developer-led land based wind farm development. A further contribution suggested that the assessment of local contributions should only include marine development within territorial waters, and for these authorities to make clear the assumptions on cable landfall. In this context, there was a request to clarify and explain "closest to where electricity might be likely to come ashore", as the point of landfall may well be unclear.

4.62 There were views that the Executive should clarify how contributions from other renewable technologies might be quantified. It was felt by some that greater benefit would accrue from providing an up to date picture of the potential to utilise the various renewable energy technologies which could be developed in an area at a range of scales of application. In particular, there was a view that more encouragement and guidance should be given to CHP schemes and heat generation technology and that these should form part of the targets for any particular area. There were concerns that where spare grid capacity existed it should not all be utilised by onshore wind, and that the SPP focus on grid capacity could be regarded as precluding any move to more localised or regional solutions to energy generation, distribution and consumption. There was considerable support for the inclusion of micro-renewable contributions within the overall area targets, although some, lesser, support for the SPP position as well.

4.63 Other points made in relation to this section included:

• a focus on whether capacity figures are being met should not be used to justify planning applications due to a perceived shortfall in a promoted area ( two NDPBs)
• there was a need for accurate and up-to-date wind speed data to be shared between the industry and local authorities if a realistic assessment of the available resource is to be made. Currently much of the data was site specific and commercially sensitive but there must be a means of making the information available (Local Authority)
• it should be clarified that a local contribution need not represent the full potential of an area to accommodate renewables where the proposed contribution is regarded as an adequate local share of national renewables targets and there is a desire by the authority to limit further impacts ( NDPB)
• it would be useful for the SPP to provide guidance on the frequency of review of local contributions ( NDPB)
• recent experience had highlighted the problems that arise through the use of broad brush macro-scale assessment. The SPP should acknowledge these possible shortcomings (Energy Businesses)
• local contributions would work as an effective cap on development (Energy Businesses)
• contributions should be expressed in megawatt hours per annum (Local Voluntary Body)
• the policy confuses the role of planning and was in danger of seeming more like an energy policy strategy (Local Authority)

Consultations on Local Contributions

4.64 Seven of nineteen respondents to this section saw a need for a National Framework to provide an authoritative context for more local contributions. Justification put forward in support if this suggestion included the argument that there should be an independent overview from the Scottish Executive to ensure local authorities are being reasonable and targets are being met.

4.65 Five respondents express concerns about the emphasis on grid capacity, one of whom observed that paragraph 42 contained the process that is intended to provide mitigation for the impacts arising from grid infrastructure upgrades and noted that, if remote areas were identified as making a major contribution, then substantial upgrade and extension of the transmission network throughout Scotland would be required. These respondents argued that the proposed consultation process would provide only trivial mitigation of the major impact of new extra high voltage overhead power lines that would be put forward by the industry and suggested that what was required was a national energy strategy so that strategic decisions about transmission infrastructure could be made at an early stage.

4.66 Among the other points raised by individual respondents, was criticism that paragraph 42 was too vague about the consultation process. There was a request for the guidance to make clear whether each planning authority would be required to set its own contribution or could work with its neighbours to create a joint target. One respondent suggested that statements on local contributions would constitute a plan or programme under SEA legislation and hence SNH and SEPA would require to be consulted.

Key Points

4.67 There were a number of concerns about what was considered the undue focus throughout the SPP towards on-shore wind, and a wish for more references to other sources of renewable energy. In this context there were comments to the effect that the SPP should highlight the main planning and environmental constraints that could affect all technologies, not just wind farms.

4.68 In relation to the suggested locational criteria, there was widespread concern that the guidance appeared to downgrade the protection afforded to natural heritage sites which were not of international or national importance, and in particular, that there was no specific protection for Regional Parks.

4.69 The proposed separation distance of 1.5km between wind farms and communities was considered inadequate, with between 2 km and 3 km the main preferred alternatives. There was also concern that no appropriate separation distance was given in the document for individual houses, nor was there any definition of what constituted a "community"

4.70 Many felt there was no explanation of why 20 MW was chosen as the threshold for a "large scale wind farm". Various alternatives were suggested and a different approach using the number of turbines and/or hub height.

4.71 Most respondents felt that cumulative impact needed to be better defined, it was more than simply a summation of visual impact and should also include 'inter alia': species habitats, archaeology and noise. Some felt that the SNH guidance was not of a format that was suitable to be recommended and that it had never been peer reviewed through public consultation.

4.72 There was considerable support for a more strategic approach to electricity grid and wind resource issues, with potential capacity developed in the first instance as part of a national strategy; possibly via links to the National Planning Framework. It was felt that this would avoid duplication of effort between, and minimize skill and resource implications for, local authorities

4.73 There was almost universal support for a greater emphasis on the use of biomass and CHP, and the provision of more detailed planning guidance, including the identification of small, medium and large scale projects. Other technologies such as energy from waste, landfill gas, hydropower, passive solar, wave and tidal energy were mentioned as well as the need to consider heat generation.

4.74 There was a strong body of opinion, that a "top down" national approach (perhaps provided by the National Planning Framework) to the calculation of local contributions, was the only realistic way to proceed. However, it was pointed out that the process would be time consuming, and there were views that it was essential that projects were not held back. It was suggested that the Executive should consider how it could support local authorities to simplify this process and ensure that it was completed quickly. Some felt that the proposal may be open to abuse by authorities and that SPP6 did not explain how the government would respond where an authority set an unrealistically low target or what "balancing mechanisms" might be adopted for over-enthusiastic authorities?