driving the low carbon economy - policy paper 5: planning
TRANSCRIPT
8/8/2019 Driving the Low Carbon Economy - Policy Paper 5: Planning
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DRIVING THE
LOW CARBONECONOMY PAPER 5: planning
RECOMMENDATIONs
✓ EnsurE a transparEnt and timEly consEntsprocEss
✓ continuE to dElivErstrong policy andpolitical supportfor all forms ofrEnEwablE EnErgy
to EnablE dElivEry of scottish and uK govErnmEnt targEts
✓ alignmEnt of localdEvElopmEnt planswith national policy
✓ EffEctivE linK bEtwEEnrEnEwablE EnErgy projEcts and thE localcommunity
✓ clarity from
statutory consultEEs
introductionThis policy paper is the fth in the Driving the Low Carbon Economy
series produced by Scottish Renewables to outline what investment
and concerted support across all levels of government is required
to realise Scotland’s ambitions of meeting at least 80 per cent of
our electricity needs by 2020. Meeting or exceeding targets will put
Scotland on a path to delivering a low carbon economy, securing
massive environmental, economic and social gains for our country.
This paper outlines the priorities for government, industry and stakeholders
towards creating effective and efcient consenting regimes that balance the
need for renewable energy development with other interests. The terrestrial
and marine planning systems in Scotland must remain modern and able
to cope with the demands of the growing renewables industry by ensuring
appropriate, effective and timely decisions.
In this paper we consider ways in which the Scottish planning system
could be enhanced to support the delivery of renewables development and
help secure the achievement of Scotland’s renewable energy and carbon
reduction targets.
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thE story so far...Scotland’s planning system is undergoing the most
signicant modernisation in over 60 years. With the
implementation changes introduced by the Planning Act currently underway there has never been a more
important time for planning.
It is the stated aim of the Scottish Government to
deliver a planning system that is: efcient, inclusive, t
for purpose and sustainable.
There is a huge amount of potential to develop
renewable energy in Scotland. To realise this we need
to ensure that the regulatory and planning regimes work
together to minimise delays, reduce costs and ensure
applications are dealt with as efciently as possible.
whErE arE wE now? At the time of writing (November 2010) there were just
over 3.5 GW of renewable energy projects awaiting
planning determination in Scotland, with onshore windaccounting for over half of this potential capacity.
With around 10 GW of offshore wind and 1.6 GW of
wave and tidal projects in the early stages of scoping,
the size of development off our shores is due to increase
massively over the next decade and beyond.
The renewables industry prides itself on maintaining
a responsible reputation and this is why a robust and
transparent planning system is so important for the
growth of the industry.
Scottish Renewables has been pleased to see a drive
from the Scottish Government towards a speedy,
efcient and inclusive planning system which has
undoubtedly assisted many projects to gain consent.
The consolidation of policy into the streamlined Scottish
Planning Policy has generally been successful and
resulted in a useful document.
We support the positive role the Scottish Government
has played in guiding local authorities within this
framework and encourage the Scottish Government
to ensure availability of resource in order to deliver an
efcient system.
The Scottish Government must continue to ensure key
messages transfer from central to local government
so that all applications are determined on their merits
against identied, broad criteria that is consistent with
national policy.
what nEEds to changE?
Align policies with obligations on Renewables
and Climate Change
As the renewables industry grows and the areas of
least constraint for development decrease, projects
need to adapt to nd the best way of achieving
acceptable design in more sensitive environments.
Equally, the Scottish Government must nd a way of
balancing competing policy agendas to ensure that
renewable energy can deliver these changes. Many of
these challenges face a common theme: the impact of
outdated regulation that does not fully take account of
the national and European obligations on renewable
energy and climate change.
fe 1. Capacity of renewables projects in the planning
system from November 2008 to November 2010.
Advocate a positive local approach
It is critical to the achievement of our renewable
energy and carbon reduction targets and to driving
sustainable economic growth that local planning
authorities (LPAs) adopt a genuinely positive approach
towards renewable energy development, recognising
both national priorities and the local socio-economic
benets of projects.
In some local authority areas, level of response to
scoping is not currently as comprehensive or upfront
as it could be. Consequently additional issues are often
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eholoe ove.
T o p f r o n t p a g e p i c t u r e : T e d L e e m i n g
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raised post submission with associated time and cost
implications. This would be improved through positive
and proactive pre-application engagement between
developers, planning authorities and consultees for
all types of projects, leading to meaningful and clearscreening and scoping advice for projects requiring an
environmental impact assessment.
A number of local authorities are recognising the
economic development potential of renewable energy,
not only from commercial projects but through, for
example, Council’s new powers to generate their own
energy. However this connection needs to be made
across all planning authorities.
Clarity of decisions from Statutory Consultees
Scottish Renewables welcomes engagement with
statutory consultees when working to address sensitive
issues, and we engage closely with Scottish Natural
Heritage (SNH) to work through issues of shared
interest and to develop good practice guidance of
mutual benet to the industry and SNH.
SNH recently produced a guidance document
conrming the agency’s approach to determine whether
impacts on natural heritage raise issues of national
interest; if they do not, SNH will only use objections
“sparingly.” This change in approach is of concern
to industry as it enables local ofcers to comment
extensively on a proposal but falls short of offering
objection or support for the project, resulting in a lack
of clarity to planning ofcers.
Consistent Local Planning Guidance
We are pleased to see the drive from the Scottish
Government towards a speedy, efcient and inclusive
planning system and we welcome the up to dateDevelopment Plans that have been drafted and
completed in accordance with SPP with appropriate
industry involvement.
However some authorities have so far failed to update
Development Plans or provide supplementary planning
guidance to reect the SPP approach, while a number
of those that have developed policies appear to have
adopted a defensive approach to renewables. Not only is
this at odds with the inclusive approach directed in SPP,
but it is also at odds with the approach to other areas
of policy development (for example, in housing, where
housing providers are directly involved in monitoring
and in strategy and policy development). The Scottish
Government should provide a clear steer to local
authorities to only develop and adopt a Development
Plan and supplementary guidance that are consistent
with national policy, and that any plan or guidance that is
adopted without consultation is likely to be given limited
weight in the determination of planning appeals.
We are also concerned that a number of LPAs
are departing from national policy and guidance.
Some have produced additional guidance, without
consultation, that diverges from national guidance.
This places additional, excessive requirements and
cost on developers and is inconsistent with nationally
recognised good practice.
Enhance link between project and community
The renewable energy industry in Scotland has a strongtrack record of positive engagement with communities
from pre-planning right through to construction and
operation of projects. This can include sharing some of
the nancial rewards and in a few cases sharing project
risks with communities.
The most successful examples of good practice are
where strong dialogue with communities has taken
place early and throughout the process and also where
a exible and voluntary approach has been applied
leading to good partnership working and a strong bond
between the community and the renewables project.
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Scottish Renewables has learned of specic instances
where local authorities have requested a proportion of
community benet payments to be directed towards
inappropriate uses, such as affordable housing.
Such requests, which are in conict with ScottishGovernment planning guidance, put the developer
seeking planning consent in a difcult position.
Communities are beneting throughout Scotland from
renewable energy projects as a result of effective
dialogue between communities and developers.
Further progress could be made through consideration
of the following actions.
Prompt implementation of General Permitted
Development Rights
Micro-renewables can make a valuable contribution
to a sustainable, low carbon economy by generating
useful energy at the point of demand. Therefore we are
pleased to see that measures are being considered
which will reduce the burden on the consumer and the
planning system, however we need a prompt decision
to allow this to happen.
Supportive advice on renewables
We support the current revision of PAN 45; it is critical
that this advice remains supportive and aligns with
government policy.
Address duplication in water licensing
There is currently duplication between planning and
the water licence processes, resulting in ‘double
jeopardy’ for developers. The planning authority as a
democratically accountable authority is best placed to
consider the social and economic impacts, including
recreation, of an application.
Effective marine planning framework
We welcome the one-stop-shop approach that has
accompanied the creation of Marine Scotland and
the level of engagement we are seeing with industry.It is imperative that the Scottish Government get the
framework right to deliver timely, efcient and inclusive
decision making.
conclusionIn order to achieve our low carbon ambitions, the
Scottish Government needs to address the increasing
cumulative, regulatory burden being experienced by
the renewables industry from a range of government
departments and agencies, whilst continuing to
ensure support for the renewables industry - which is
clearly present at national level - is properly reected
in local plans and supplementary guidance. This
requires ongoing monitoring of the implementation
of the modernised planning system, and the Scottish
Government needs to be prepared to make changes
where necessary to ensure it is delivering its aims.
The above examples are only a relatively small - yet
signicant - proportion of the regulatory pressures being
faced by the industry. Combined, these constraints
threaten the ability of the industry to deliver projects
at reasonable cost, and to meet Scotland’s renewable
energy targets and ambitions for 2020 and beyond.
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c p p me : rosiE vEttErE-: e@eee. | te: 0141 353 4987
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