The Scottish Government’s National Planning Framework 4 (NPF4) is Scotland’s long-term spatial plan that sets out where development and infrastructure is needed to support sustainable growth.  Consultation on the Scottish Government’s NPF4 Position Statement ended on 19 February 2021.

The Position Statement sets out the Scottish Government’s current thinking on the content of NPF4 and potential policy changes.  The draft NPF4 will be published in autumn 2021 when there will be a further period of consultation.  It is expected that NPF4 will be adopted by the Scottish Parliament in spring 2022. When it is adopted, NPF4 will replace the current National Planning Framework 3 and Scottish Planning Policy and will be a material consideration in planning decisions.

Planning for net-zero

The key driver of NPF4 is the need to tackle the climate emergency and to achieve net-zero emissions by 2045.  The Position Statement recognises that an urgent and radical shift in planning policy is needed if Scotland is to meet its emission reductions targets of 75% by 2030 and 90% by 2040, achieving net-zero in 2045.

Facilitating the rollout of renewable electricity and renewable and zero emissions heat technologies will be a priority for NPF4.  The Position Statement recognises that significant further investment will be needed to support new technologies for carbon capture and storage; hydrogen; sustainable and active travel; electricity grid capacity (including subsea links to the islands); and decarbonisation of heating, transport networks and vehicle fleets.

The Position Statement floats the possibility that infrastructure such as carbon capture and storage infrastructure, on and offshore renewable energy generation and networks, and clean hydrogen production and distribution could become national developments in NPF4.  Designation as a national development would bring with it a presumption in favour of the development when applications for planning permission are considered.

Support for renewable energy developments

There are a number of proposed policy changes supportive of renewable energy developments as part of the net-zero emissions strategy. These include:

• strengthening Scottish Government support for repowering and expanding existing windfarms;
• new policies to address a wider range of electricity generation technologies, e.g. electrical and thermal storage and hydrogen;
• facilitating development that is highly energy efficient, including making provision for zero carbon energy generation; and
• the Scottish National Investment Bank to use its investments as part of the drive towards a transition to net-zero emissions, in line with its primary mission.

As well as supporting standalone renewable energy developments, the drive towards net-zero will present opportunities for small scale renewables to be embedded within developments. However, balanced against these positive statements are some proposals that could make consents for renewables developments, especially on-shore wind, harder to obtain, such as restricting development on peatland and shifting future development away from greenfield land.

Scottish Renewables response on NPF4

While the proposals in the Position Statement for achieving net-zero are broadly to be welcomed, it is likely to be at least another year before NPF4 is adopted.  In view of the urgent need to tackle the climate emergency, Scottish Renewables has suggested in its response to the consultation that interim measures be introduced to support renewables development.  These include:

• a direction from the Scottish Ministers that the planning balance should be tilted in favour of the climate emergency and net-zero;
• the introduction of an immediate presumption in favour of repowering of wind farms, and
• an urgent review of improvements to the consenting process needed to deliver timely consents.

What more can be done?

Policy support for renewables is all very well but few would disagree that, if the transition to net-zero is to be achieved, an overhaul of the consenting system will be required to produce quicker decisions.  There is concern that the consenting system for new technologies, such as carbon capture and storage and hydrogen networks, needs to be developed.  It is to be hoped that, in parallel with the adoption of NPF4, the Scottish Government will turn its attention urgently to making the consenting system fit for purpose.

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