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Executive Summary

Context

The Scottish Executive published draft Scottish Planning Policy ( SPP) 6: Renewable Energy on 10 July 2006 and responses were invited from a wide range of organisations and individuals by 6 October 2006. This deadline was subsequently extended to 20 October 2006. A total of 1020 submissions were received by the deadline for comments (excluding 2 duplicate responses and including 7 from MSP's endorsing the views of their constituents). Around 800 of the responses were specific to 3 campaigns. The issues raised by these campaigns, and the interest each one generated, will be taken into account by the Executive. However, as the content of campaign responses was almost always identical, the primary purpose of this report is to highlight the additional substantive comments made by other respondents.

Project Objectives and Methods

The main purpose of the project was to provide an analysis of the comments received to the Draft SPP so as to highlight for Scottish Ministers the key issues raised by respondents during the consultation. Responses were inserted into a linked consultation database containing text and numerical fields relating to the 6 main respondent categories which had been identified, (local authorities; public bodies; business and trade organisations; professional and academic organisations; community councils and voluntary sector; and the public and politicians/political groups). The Draft SPP contained 2 specific questions, and the document was organised in a hierarchical structure relating to paragraph numbers and this was reflected in the database which comprised 80 fields. This enabled statistical tables to be created, and in-depth qualitative analysis of the main elements of the SPP to be carried out.

Comments Made on the Draft SPP

General Observations

There was overwhelming support for the production of revised guidance on this topic. It was thought to be timely given the substantial current pressure to develop renewable energy sources. 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. 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

Supporting Renewable Energy

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. There were, however, widespread views that the document was less balanced than was desirable in respect of renewable energy technologies other than on-shore wind. There was also a cluster of responses advocating a more directive and holistic national approach to energy planning.

SPP Principles

Nearly 80% of respondents broadly supported the approach set out in paragraphs 8 and 9 of the draft SPP. As a group, business respondents had the most reservations about the approach. There was a group of responses suggesting that there should be a role for the National Planning Framework and there was also support for the need to keep this policy area under review as well as an updating PAN 45 which could provide information on new technologies.

Just over two thirds of respondents supported the general 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) against the "broad areas of search" ( BAS) approach, while most other groups tended to be generally in favour. Those with reservations felt the BAS approach would be too crude and broad brush, given the many factors that could affect commercial and environmental suitability. However, some groups of respondents, mainly from the voluntary sector and private individuals, felt that the BAS approach should be tightened up.

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.

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 and many felt that the national economic interest should be paramount. 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 while some felt there was much more potential in the emerging offshore technologies.

Spatial Policies and Locational Considerations

Several respondents made the general point that the SPP should highlight the main planning and environmental constraints that could affect all technologies, not just wind farms. In relation to the suggested locational criteria, the main areas of concern were that:

• the guidance appeared to downgrade the protection afforded to natural heritage sites which were not of international or national importance
• the suggestion that there should not be "buffer zones" around major natural heritage assets, although there was also some support for this
• the absence of specific protection for Regional Parks
• the perceived equivocal stance of the guidance on the impact of wind farms on tourism; from both promoters and objectors
• the proposed separation distance of 1.5km between wind farms and communities was inadequate. There were many suggested alternative distances but the most frequently mentioned were between 2km and 3 km
• no appropriate separation distance was given in the document for individual houses, nor was there any definition of what constituted a "community"
• 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 recommended by some respondents
• 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
• the SNH guidance on cumulative impact 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
• wind resource should be considered in the first instance at national level as this would avoid duplication of effort between, and minimize skill and resource implications for, local authorities
• a more strategic approach to electricity grid issues 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
• grid capacity should follow, and thus enable, the exploitation of identified wind resources and hence BAS should not be limited to currently available or planned grid capacity

Biomass and Other Technologies

There was almost universal support from respondents to this section who believed the guidance should place a greater emphasis on the use of biomass and CHP, and provide more detailed planning guidance, including the identification of small, medium and large scale projects. There were concerns about what was considered the undue focus throughout the SPP towards on-shore wind, and more references to other sources of energy 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.

Local Contributions

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 ) was the only realistic way to proceed with the assessment of local contributions. There were views that indicative regional figures should be established which could then be apportioned by agreement between groups of planning authorities.

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. 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?

There were views that the Executive should clarify how contributions from all types of renewable technologies might be quantified and in particular, a number of concerns and queries regarding the approach in respect of offshore renewables.

Micro-renewables

There was almost universal agreement amongst respondents that micro-renewables should be encouraged. Notwithstanding the reference in the SPP to the intention to publish a separate Energy Efficiency Strategy for Scotland, many respondents felt that the guidance here regarding new and existing buildings should have been framed within advice regarding the range of measures needed to reduce energy consumption and increase its more effective use in buildings, as well as encouraging the development of more sustainable forms of generation. Views were relatively evenly split, and also varied across all respondent groups, on the desirability of using permitted development rights to encourage the positive uptake of micro-renewables.

Most development industry respondents raised some concerns regarding the requirement to consider options for micro-renewables in new developments. In particular, the likely cost which house purchasers would have to bear was frequently cited and there were various suggestions for financial support schemes or tax breaks to be introduced as incentives.

The greatest proportion of comments, (120 individual submissions - 52% of all responses), were received on the proposed 10% target CO2 reduction policy standard. Around half of all the responses considered that the suggested level was too low and more ambitious targets (varying from 15-50%, but with 20% most frequently cited) should be set. These views were most prevalent amongst voluntary body and individual respondents but a number of energy businesses also thought higher levels were attainable. There were numerous comments to the effect that any target should be seen as a minimum requirement and many also suggested that it should be steadily increased on a year by year basis.

With respect to the developments to which the policy should apply, there were a number of positive references to the London Borough of Merton's policy which related to proposals for 10 + houses or 1000m2 of non-residential property. Others sought wider definitions - several suggested a 500m2 threshold and there was considerable support for all residential and non- residential properties. The question of implementation was interpreted very widely by respondents and there was little consensus regarding the most appropriate way forward, although significant concerns were expressed about skill deficiencies both within the planning profession and building industry.

Development Planning

Few respondents dissented from the view that there should be a positive role for the Development Plan in planning for renewable energy, but those who had previously expressed concerns regarding the BAS approach and local contributions assessments reaffirmed their opposition. In addition there were a number of representations seeking clarification or additions to the criteria set out in paragraph 47.

A number of local authorities and some professional bodies expressed concern that the draft SPP only referred to Local Plans and felt that there was a clear role for Structure Plans in this process as well. A number of concerns/queries were expressed (mainly by local authorities) about the SPP's intentions regarding updating the development plan in relation to renewable energy issues (paragraph 48). Some respondents questioned whether if there was current partial compliance with the SPP approach, an immediate review was necessary and argued for more flexibility. Others wanted clearer guidance about whether a Development Plan update or Supplementary Planning Guidance ( SPG) was the preferred way forward.

Development Management

There was relatively widespread support for the approach regarding pre-application discussions. Comments tended to focus on the need to clarify or develop the advice further. Few took exception to the need for community consultation, but there were concerns from various quarters that such views did not always effectively feed into the decision-making process. There was a considerable amount of concern about the integrity of the EIA process as applied to wind farm developments. Energy businesses expressed concerns about the necessity and wisdom of undertaking risk assessments, which it was felt would raise safety fears and increase community objections to proposals. There was general support for the advice that the level of assessment should be related to the scale of the proposal.

Views on the assessment of environmental, social and economic benefits were quite polarised. Some felt that the need for proposals to contribute (especially national) economic benefits should be strengthened and that the degree of benefit should be a material consideration; others that the whole section should be deleted, as such benefits could not be secured by planning conditions or agreements, as they may not be within the power of the developer to deliver.

Grid connection issues had already been raised in comments on paragraphs 33-35 of the SPP and there were few additional comments at this point. While there was some clear cut support for the approach in the consultation document, the predominant views were of some confusion or uncertainty amongst respondents.

The approach in the SPP on considering applications was broadly supported by local authority, voluntary body and individual respondents, while energy businesses, public bodies and professional respondents expressed the most concerns. There were views that references to the consideration of adverse impacts should be strengthened and include more guidance in relation to secondary development (construction and maintenance of access roads, cable routes etc.). Several energy businesses thought that calculating the impact on climate change would be virtually impossible, while a voluntary body suggested that it would be better to be framed in terms of CO2 reductions achieved over the whole life of a project. Most energy businesses were opposed to the need to consider alternatives to proposals; on the grounds that it would be difficult to prove that all options had been considered, that it would open the door to endless objections and moved away from the principle of considering applications on their merits. Supporters of the approach, however, thought it should be strengthened in the SPP.

Issues Raised Outwith the SPP Structure

Respondents raised a number of issues not directly addressed in the SPP and concerned with the wider energy policy agenda. These included:

• Additions to Annexes A and B
• Updating PAN 45
• Radio and TV Interference
• Energy Conservation and Efficiency
• Coal and Nuclear Energy
• Renewable Energy Department
• Third Party Right of Appeal
• Mapping Progress with Wind Farm Developments
• Brownfield Development
• Scottish Energy Strategy
• Electricity Grid Upgrades
• Demonstration Projects
• Electricity Acts

Strategic Environmental Assessment

There were four main elements to the SEA on which respondents may have wished to comment. In practice, there was only one separate submission relating to the SEA and two other comments which were included in the main SPP submission. These covered only 3 of the 4 parts of the SEA.

An NDPB was disappointed that the SEA did not assess the environmental impact of various renewable technology mixes, and illuminate how the Executive's 2020 target could be met with least environmental impact. They felt that the issue which was of greatest importance and of prime public interest, was the extent to which renewable energy development should be allowed to impact upon non-designated resources and that an opportunity would be lost if SPP6 did not offer guidance on this issue. The respondent was also disappointed that in section 4.2.6 of the SEA, the baseline data did not include information on Scotland's wild land resource.

In the view of the NDPB, it would be possible, helpful and desirable to offer planning authorities some level of national guidance on the capacity of different parts of Scotland to accommodate renewable energy, as envisaged under Option E - regional targets. A submission from another respondent was concerned that the SPP was silent and hence rather dismissive of the potential environmental impact of hydro schemes.

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