Renewable electricity generation in Scotland reached record levels in 2017, according to official data. Statistics published by the UK government showed an increase in Scotland of 26% in 2017, compared with the previous year. The majority of this increase was attributed to greater onshore wind capacity. The data also showed that by the end of 2017, just over 10GW of installed renewables electricity capacity was operational in Scotland. It is estimated that the equivalent of 68.1% of gross electricity consumption in Scotland came from renewable sources, up year-on-year by 14.1 percentage points. In commenting on these figures, Scotland’s Energy Minister, Paul Wheelhouse, confirmed that renewable energy will continue to play a hugely significant role in powering Scotland’s future.
As those people who are concerned at the proliferation of wind turbines in the Scottish Borders will know, Scottish Borders Council has been relying on its 2011 Supplementary Planning Guidance on Wind Energy, large parts of which are out-of-date in relation to Government policy, when determining applications for wind energy developments. When the Scottish Borders Local Development Plan was adopted in May 2016, it included an intention to produce up-to-date Supplementary Guidance on Renewable Energy, including wind energy, within one year of the adoption of the local development plan.
The council published Draft Supplementary Guidance on Renewable Energy in December 2016 for consultation with interested parties and, after a prolonged period of deliberation, a final version of the Supplementary Guidance has now been approved by Scottish Borders Council for submission to Scottish Ministers. It is vital that the Council has up-to-date Supplementary Guidance in place, which takes cognisance of all relevant national planning policy and guidance, when assessing and determining wind farm proposals. It also strengthens the council’s position when defending its refusal of planning permission for wind turbines and wind farms at planning appeals.
National planning policy promotes renewable energy developments to facilitate the transition to a low carbon economy. The Climate Change (Scotland) Act 2009 requires all public bodies to mitigate the causes of climate change. The Government’s National Planning Framework (NPF3) and Scottish Planning Policy (SPP) are supportive of renewable energy. Policy ED9 in the Scottish Borders Local Development Plan states that the Supplementary Guidance on Renewable Energy will accord with Scottish Planning Policy; this requires an onshore spatial framework identifying areas where wind farms will not be acceptable, areas of significant protection, and areas with potential for wind farm development; a contentious issue amongst those communities which have concerns about the impact of wind farms on the landscape and rural communities.
In terms of wind energy, the Supplementary Guidance, therefore, sets out a spatial framework as required by SPP, and incorporates an update of the Ironside Farrar Landscape Capacity and Cumulative Impact Study of July 2013, which has been the subject of intense scrutiny at recent planning appeals. Although wind energy is the main component of the SG, reference is also made to a range of other types of renewable energy development, including micro-renewables such as photovoltaic panels, field scale solar voltaics, biomass, energy from waste, anaerobic digestion, hydro and ground source heat pumps. The SG provides useful background information and good planning practice guidance on each of these energy types.
The spatial framework for wind energy proposals, which applies to all turbines that exceed 15m in height to blade tip, has been generated through a comprehensive sieving exercise of constraints, including national and international landscape and conservation designations and the visual impact on communities. Figure 6 in the SG shows the results of this exercise and to the consternation of many people, I am sure, a large part of the Scottish Borders lies within the area designated as having potential for wind farm development.
However, compliance with the spatial framework is only one consideration in determining whether a wind farm proposal is acceptable. Policy ED9 of the adopted local development plan identifies a comprehensive list of other considerations. These are set out in chapter 8 of the SG and include:
- Landscape and visual impacts;
- Effects on Wild Land;
- Cumulative impacts;
- Impacts on communities and individual dwellings in the countryside;
- Impacts on carbon rich soils;
- Impacts on public access, the historic environment, tourism and recreation;
- Impacts on aviation and defence interests and seismological recording, telecommunications and broadcasting installations;
- Impacts on adjacent trunk roads and roads traffic;
- Effects on the natural heritage (including flood risk);
- Opportunities for energy storage;
- Net economic impact;
- Contribution to renewable energy generation targets and effect on greenhouse gas emissions; and
- Decommissioning and site restoration.
Also, whilst the spatial framework identifies areas of protection and areas with potential for wind farms, it takes no cognisance of landscape capacity issues, which are material considerations for wind energy proposals. Consequently, outputs from the Ironside Farrar Landscape Capacity Study must be referred to as well as the spatial framework. If turbines are proposed which exceed the turbine heights identified within the Ironside Farrar Study 2016, the onus will be on the applicant to demonstrate how the impacts of the proposal on the key constraints and any unacceptable significant adverse effects can be mitigated.
It will be interesting to see what Scottish Ministers have to say about this new Supplementary Guidance for I am sure that the Council will want to see it approved and incorporated into the local development plan as soon as possible. As well as providing advice to applicants/developers on the wide range of issues to be addressed within their submissions, the SG should also enable development management officers within the Planning Department to provide clearer guidance on wind farm related considerations, and process applications more effectively and efficiently.