Consultation Draft Revision of NPPG6: Renewable Energy Developments
Digest of Responses Received
Policy Content : Renewable Energy
Policy Guidelines : General Principles
Additional Policy Guidelines forIndividual Technologies
Digest of Responses Received
- The draft revised version of NPPG 6 : Renewable Energy was issued for consultation on 1 st June 2000.
- This digest has been prepared by the Scottish Executive to help reference to the spread of detailed responses received.
- Our aim has been to reproduce the essence of comments fairly, grouping the material by paragraph to allow cross-reference between the views of different consultees.
- Inevitably, views on some issues may be dispersed across more than one paragraph.
- In drawing all the material together, we have done our best to avoid errors of transcription, meaning, attributions,
- omissions, or otherwise and we apologise for any that occur.
- Where paragraphs are not referred to, there have been no comments made.
- Abbreviations used are explained in the Annex.
BWEA: Welcome statement re SE commitment to renewables.
DGC: (Also refers to Para 13) Requires more information on SRO schemes, what effect deregulation of the electricity industry will have on renewables and how changes will be implemented in England & Wales as NFFO proposals have occurred in Scotland.
NWP: Para 1-6 Welcome statement strengthening policy - note new guidance will speed up consideration process.
RDC: Strongly approve.
SRF: Welcome the move by the SE to recognise the need for an increase in renewable energy developments in Scotland.
FR: In addition to the key vehicles of the Utilities Bill and the Renewables Obligation, the DETR regional assessment of renewable resource, setting of locational renewables development targets under Regional Planning Guidance, and the MAFF Energy Crops Establishment Scheme approaches will be required for Scotland's renewable energy resource.
RTJ: Less visually intrusive developments should not be neglected. Unfortunate for Scotland if wind farms given undue emphasis.
Definition of Renewable Energy
BEn: "combustible or digestible industrial, agricultural or domestic waste materials are also regarded as renewable sources of energy'. Not
clear if use of landfill gas classified as a renewable source of energy.
DMJ: Concerned over inclusion of energy from waste as a renewable energy technology. No mention of tidal power.
NSW: Accept biomass as a potentially renewable energy source. However consider that a distinction should be made between the combustion of these resources and the combustion of industrial and domestic waste streams.
RSPB: Questions whether the combustion of non-organic waste is a renewable energy source. Given that the NPPG adopts a strong pro-renewable development stance concerned that 'Energy from Waste' processes are included within the renewables family. Strongly recommend that a third term be used, that of 'recoverables' which more accurately reflects the process involved and would allow planning authorities to adopt a sequential or hierarchical approach to energy developments within development plan policies. To avoid confusion over Reserved Powers 'recoverables' could be considered as a less sustainable sub-set of renewables.
RTPI: Questions whether combustion of non-organic waste is renewable energy source - define as recoverables allowing hierarchical or sequential approach. Guidance on energy recovery to be in NPPG 10.
SRF: Other technologies that should fall under the remit of NPPG6 include solar thermal and biomass for heating.
HC: Threshold for hydro schemes being determined under the Electricity Act to be raised above 1 MW.
RSPB: Experience of SRO process not been particularly positive. Welcome proposed Utilities Bill and encourage the SE to recognise that whatever replaces SRO will have to enable more appropriate and environmentally sound proposals.
Encourage SE to support the creation of interim regulations to facilitate greater flexibility for developers seeking planning permission for contracts awarded under the SRO. As SRO contracts were awarded purely on the basis of price, environmental issues were not considered in the assessment of applications. Interim regulations and the new RSO should aim to remove these obstacles and reduce pressure on environmentally sensitive sites.
RTPI: Reference to be made to the consultation process set up in Annex F of the SE/DTI concordat of 25/11/99.
HA: If SRO projects run out of time by statute, it should not be open for rules to be changed by the Scottish Parliament retrospectively as paragraph suggests.
KGB: No regard for conservation issues raised by developments.
PR: This point encourages consistency and clarity.
RA: Noted change from the concept of providing appropriate checks to developments to language stressing assisting development.
RM: ".....including those projects still to be implemented under SRO's 1-3. " to be defined more specifically.
A reasonable compromise would be to indicate that those proposals for which planning consent is sought after the ratification of the new guidelines utilise the new guidelines. Those for which a planning application has already been submitted would use the pre-existing guidelines.
RTPI: 1 st line "Government " means "UK Government". These refer to "factors " and not "considerations".
SWLG: Concerned with "those projects still tom be implemented" - new NPPG only to be of relevance to new applications.
RSPB: Support current review and are happy to work with SE in progressing work.
APRS: Smaller stand alone projects to be positively encouraged.
BWEA: Welcome statement that guideline is applicable to all projects, regardless of size. However, note that in Para 66 it states that the impacts of smaller developments will be lesser and that development plans should recognise this and that the information required to support planning applications should be less extensive. These clauses therefore might create some confusion.
Concerned that there is some confusion between "small", "commercial", "stand-alone" and "non-grid connected". All sizes of project might be grid connected, though agree that stand-alone (not grid connected) projects are likely to be smaller.
"count towards the renewable energy targets" might prejudice against such projects within planning. No government policies, to their knowledge, that states that non-grid connected or small projects do not count towards the targets. It is unlikely that stand-alone (not grid connected) projects will not be supported under the provisions of the Utilities Bill, but expect that small projects will be.
The references to "commercial" projects might also be misleading as it is likely that smaller projects will come forward that are also commercial in nature (i.e. not for domestic use).
Propose the following wording:
"This NPPG relates to all renewable energy projects. Whilst the majority of applications are expected to be from larger grid connected projects, smaller scale projects, including those that are stand-alone (not connected to the electricity grid) should also be expected. Such smaller projects can play a valuable role in renewable energy production and meeting the commitments to tackling climate change. All applications for renewable energy schemes should be considered against the principles set out in this NPPG."
CNES: Regrettable that appears to dismiss small-scale developments. Wishes to see document highlighting and giving encouragement to such developments. Could make significant contribution to rural and island communities.
FR: Welcomes recognition of role that smaller scale, stand-alone renewables project can contribute. Irrespective of scale, these projects if successful, can also be commercial. If a distinction to be made on generation capacity as to whether the project contributes to meeting the Scottish renewable energy target, limits need to be agreed, defined and communicated.
HE: Finds confusing and suggests whole paragraph is re-worded.
RA: Should be presumption in favour of small-scale community, local or regional projects.
RTS: Smaller projects should be part of renewable energy targets.
SNH: Suggest scope widened to include all types of renewables.
2 nd sentence - extend to include medium sized units serving a number of consumers but not connected to grid.
SRF: Guidelines need to be clearly applicable to all renewables developments, regardless of location, scale or market demand.
Policy Content : Renewable Energy
BWEA: Reinforce the fact that the effects of global climate change are being experienced today and suggest that final sentence is worded as:
"Unless greenhouse gas emissions are brought under control, these will have severe and unpredictable global impacts which, in turn, can lead to significant effects at a local level - effects which are already being experienced in Scotland".
DMJ: Para 7 - 13.
Logic of sustainability would suggest over 100% of new capacity should be renewables to take into account increase in energy consumption. Current policy has effect of increasing supply of energy from fossil fuels.
It would be helpful to have information on meaningful measures such as installed capacity of wind turbines.
HA: "legally binding target" being ignored by others does not excuse SE from explaining proposed measures.
Actions by SE not consistent with broader actions by the UK government re cars etc.
HC: Cross-reference to precautionary principle appropriate.
HP: Even renewables produce pollutants. SE should be trying to reduce greenhouse gases and these pollutants.
RA: Notable in its exclusion, in its new form, of any mention of possible adverse effects.
RSPB: Effects of climate change are already being experienced in Scotland, with Scotland's biodiversity acting as an indicator of the changes in temperature, sea levels and weather patterns.
RTPI: "Concern for the environment" not appropriate, suggest "Climate Change and the environment".
Suggest further paragraph explaining context of sustainable development particularly re environmental case for wind farms.
SNH: Also Para 8 - Strong cross-reference needed to need for energy conservation and how planning system can be involved.
SRF: Should reinforce the fact that the effects of global climate change are being experienced today in Scotland.
SWLG: Para 7 - 13 Looking for research to show use of renewables leads to less burning of fossil fuels.
Concerned renewables rely on long-term subsidies being used for projects which can cause environmental harm.
CSCT: Support general principles set out in Paras 9 - 11.
MEGA: For SE to show commitment to reducing fossil fuel use, must stop approvals of open cast coal sites.
HA: Wind farms lead to greater greenhouse gas emissions as they force conventional power stations to work less efficiently.
HP: See Paragraph 7.
RA: Insert 'a wide variety of' before renewables to change emphasis from wind farms to wider variety of technologies.
BEn: Delivering the existing SRO targets by 2002/2003 is a difficult challenge as based on current project development, there will need to be an increase in the rate of projects commissioned to 100 MW/year.
BWEA: See SRF comments.
CNES: Para 9-11 Contradicts Para 6 of NPPG 16. Fails to address issue of oversupply which exists in Scotland. Could help by providing planning context for English and Irish interconnectors.
DGC: Requests information on how SRO decisions are made. Needs to refer to NFFO especially as to whether such schemes are considered to be part of Scottish target if sited in Scotland. Clarification required as SE previously expressed view that their structure plan is well placed to deal with such applications for wind energy developments.
MEGA: Why is 150MW of new capacity required when power plants not running at capacity?
NWP: Maximum figure of 11% for hydro, with intermittent rainfall recently seeing this fall to 7%. May need to revise Scottish targets upward (see Para 12).
HP: The paragraph should quote the progress towards the reduction in greenhouse gases from power generation.
RSPB: See Para 3.
SRF: When using generating capacity figures it should be clear as to whether these relate to either installed / name-plate capacity or to the declared net capacity (DNC).
The figure of 11% hydro contribution is at the upper range of annual production and believe annual average output ranges from 7 - 11% of total electricity demand.
BWEA: See SRF comments
DMJ: In addition to promotion of wind power, should percentage of renewables be required after 2010, stronger encouragement is needed for alternative technologies such as forest waste and energy crops.
FR: 2010 and 2012 targets not the end of the story.
HA: When are consumers asked if costs are acceptable?
MEGA: SE to put more effort and investment into renewable energy.
NWP: The reference to 'subject to the cost to consumers being acceptable' is not universally found in government statements and should be omitted.
RA: Final sentence to be given stronger resonance.
RDC: Seeks to emphasise that this is a continuous process and will extend beyond current ambitions.
RSPB: Welcome the final sentence recognising that planning authorities will have to continue to address renewable energy demands well beyond the 2010 target and recommend that this factor be given even greater prominence.
SRF: "cost to consumers" could be mis-construed within planning guidance, believe refers specifically to the direct financial cost to electricity consumers and not the external or environmental costs - prefer this statement removed from the NPPG.
FR: Electricity suppliers not be best placed to decide how best to meet this obligation
GCC: Should issues relating to pricing figure in this NPPG, particularly if they represent standard business practice? The paragraph should be excluded. If it must be left in, the end of the paragraph from line 2 should be altered to read ".siting of projects and any additional cost of the electricity generated, that may have to be passed on to consumers". Would allow fiscal and other changes that operators may face in the future to be taken into account.
RA: Percentage targets for each technology alongside assistance to less developed technologies.
SNH: Downplays role of LA/SE in siting renewables - inappropriate to imply decisions being left to electricity suppliers. Add at end of paragraph "It will be for suppliers to propose the siting of projects within the framework offered by national planning guidance and local authority development plans".
BEn: Developing renewables beyond the existing SRO targets to meet the proposed 17.5% supply by 2010 will require significant changes in the energy sector within Scotland. Changes to planning guidance to address renewable welcomed, but are only part of a suite of issues that must be addressed in order to achieve the 17.5% supply target.
DGC: Role of LA needs to be explained in relation to offshore projects as likely to be a consultee and development has implications re on-shore development. Information already being gathered in the Solway Firth.
FES: Suggest 22.5% by 2010 and a 50% target by 2025.
FR: 1999 DTI consultation document on new and renewable energy recognised the different strategic timescales from implementation of the types of renewables technologies. Technologies such as hydro, onshore wind and energy from waste (incineration and landfill) will contribute most during the short term (i.e. by 2000). Offshore wind, like biomass will contribute significantly in the medium term (~ 2000 - 2010). The long and very long-term technologies, emerging after 2010 include photovoltaics, hydrogen, wave and tidal power.
MCS: Also Para 13 - feel too dismissive of offshore power, would like to see more positive commitment from SE.
MEGA: Suggests more needs to be done south of the border.
RA: Energy needs met from as wide a range of technologies as possible.
RSPB Scottish target may not be ambitious enough. As a potential leader in renewable energy, it may be appropriate to aspire to meeting the EU aim of increasing overall share of renewable sources to 23.5% of electricity by 2010.
Sound guidance, clear technical advice and sufficient resources are essential regardless of which target is adopted.
RTPI: Indication of trends in supply and demand appropriate.
SCF: In the longer term tidal stream energy technology will have a role to play - reference should be included.
SNH: Issues similar to bringing fish farming into the planning system re offshore developments.
WTS: Welcome recognition of potential for renewables.
APRS: Why is SE not encouraging offshore wave and wind?
BBS: Emphasis on wind farms misconceived as this type of development attracts most opposition - this is likely to continue if they are to be concentrated in the central belt and South of Scotland.
BEn: Placing stand-alone developments outside the remit of the new obligation is to marginalise some technologies and remove incentive for new entrants into the market, particularly in the domestic and industrial market.
BWEA: See SRF comments.
CKA: Feels offshore wave and wind developments being sidelined for short term economic reasons.
CNES: Also Para 64 - too dismissive of marine locations for development. Could encourage as part of civil engineering schemes such as causeways. Raise different planning issues.
CT: Offshore wind and wave will require special funding - when cheaper onshore schemes up and running, probable offshore schemes will be shelved.
DGC: Disappointing to note individual turbines outwith new obligation - have potential as cause less of a degree of concern than larger schemes.
DMJ: Concerned that focus on wind does not equate to "dash for gas".
FES: Lack of guidance on wave and offshore wind is a serious omission. SE should be more enthusiastic.
FR: Planning system should not try to pick winners.
GCC: Given the emphasis placed on wind farms, hydro, waste-to-energy and biomass developments to achieve the Renewables (Scotland) Obligation is considered that the urban environment offers fewer opportunities for major development, with the possible exception of waste-to-energy. However, as stated in Para 6, a number of smaller stand alone projects can be expected which should also be assessed against the principles set out in NPPG 6.
HA: Comments re offshore wave and wind contradict speech in 1998 by John Battle.
Electricity suppliers more interested in cash.
HE: Replace "to a lesser extent" with "plus" as de-emphasises biomass.
LEC: Why should stand alone renewable energy developments fall outwith the scope of the new Obligation? Given the right market stimulus domestic wind turbines could provide a significant cumulative impact on the ability of individual households to offset carbon dioxide emissions.
MCS: Too dismissive of stand-alone developments - should make more positive comments and offer more planning guidance.
MEGA: Lack of funding has prevented growth in production from wave power. NPPG is a good opportunity to promote small-scale developments which suggests can have significant cumulative effect. Suggests equipment to be VAT exempt.
NP: 2010 figure should be seen as a minimum not a target. Once figure reached considered the weight given towards subsequent applications may be reduced - not felt guidance intends this and should be re-phrased.
NWP: Much of the new capacity will derive from on-shore wind. Offshore wind has limited potential because the seabed tends to slope very steeply and because technically suitable estuarine areas tend to have Ramsar constraints.
RA: Important to establish mechanisms which will protect the Scottish landscape from inappropriate and insensitive development.
Absence of policy guidance for wave and offshore wind may serve further to restrict their application.
Special funding provided for offshore wind and wave power developments to ensure commercially viable when onshore wind has been exhausted.
Why has the commitment to R + D been omitted from the new draft guidelines.
RDC: Ability to develop offshore wind energy projects not necessarily needs special funding - suggests say that will follow behind developments on land.
RM: Finds statement re wind farms counter-productive.
1) as amount of electricity which on-shore wind power stations can generate is tragically low in the context of our energy need,
2) Wind-turbines draw capital away from other forms of renewable which may better suit the needs of Scotland,
3) On-shore wind is unlikely to provide large-scale employment in Scotland, and
4) Scotland has more to lose by inappropriate development of on-shore wind power than almost anywhere else.
Best to make no presumption that any particular form of renewable will be the major contributor.
RSPB: Absence of policy guidance for wave and offshore wind may serve further to restrict the application of these technologies - should provide as comprehensive a framework as possible.
Would welcome clarification on the regulatory mechanisms which would apply to development below low-water mark.
SCA: NPPG is insufficiently confident that small-scale schemes can count towards national targets.
SCF: Should acknowledge the "significant" (rather than "limited") contribution that offshore wind and wave power could make in the long term when the technology is utilised fully.
SEPA: Offshore wind and wave may become more important through special funding and if becomes more important may require special guidance. Noted no planning framework in PAN 45 for handling wave power developments and ancillary works on-shore.
SNH: Too lightly dismisses offshore developments. Suggests - "It is expected that during the early years of the Renewables (Scotland) Obligation much of the new capacity will come from onshore wind, and to a lesser extent hydro, waste-to-energy and biomass developments. Initially, offshore wind and wave power developments may have a limited contribution to make, but offer the potential for proposals with relatively environmental impacts. Although outwith.."
SRF: Do not agree that off-shore wind and wave projects will only come forward on the basis of "special funding" - feel this may prejudice views against such projects.
Photovoltaic panels likely to be an eligible technology under new supply obligation "stand-alone" systems should not be treated in any way differently from grid connected projects.
WTS: Biomass encouraged to make more of a contribution to RSO - like to see statement that most new capacity will come from biomass.
ACC: Para 14 - 16 Grid upgraded as a priority. Not acceptable that renewables will be concentrated in the central belt area.
APRS: Map is of poor quality. And not helpful.
Encouragement should be given to councils/consumers to reduce energy consumption thus taking pressure off the grid.
Welcome development in central belt - brownfield should take precedence over unspoilt landscapes.
BEn: No quantification of capacity that could be accommodated in southern Scotland without need for grid strengthening, nor who will bear the associated costs. These issues need to be raised within the current review of the 1993 study of the Scottish renewable resource.
BWEA: Inappropriate to link planning guidelines to any constraints within the electricity grid system. Issue may be resolved with the introduction of a Single System Operator within the Scottish electricity system.
Clause might be used to suggest that there is a policy basis against wind farms outside the central belt and southern Scotland and hence form a bias against projects outwith that area.
Concerned Map 1 oversimplifies the electricity network and may cause incorrect conclusions to be drawn about the potential locations for renewable energy projects.
CSCT: See comments concerning Para 22.
CNES: Para 14-16 Western Isles has great potential for renewables. Seek public access to grid review. Guidance needed on assessing new grid proposals. Seeks SE commitment to improve connections between the mainland and islands.
DGC: Particular concern about proposal to increase targets given grid constraints. Consider disproportionate number of applications for wind farms will be for their area. DGC request SE to give serious consideration to improving grid capacity to ensure renewables spread over whole of Scotland.
Disappointed to note restrictions in grid remain since 1993.
DMJ: See SLF comments.
FCom: More emphasis to contribution of small-scale stand alone schemes that need not contribute to the grid and therefore not constrained by grid system. Overall contribution of many such small schemes could be significant, especially in rural areas.
HC: Is this assertion over-pessimistic when reconciled with proposals issued under SRO 1-3?. Expresses concerns that grid capacity could be disadvantageous re economic benefits. Up to date assessment required for final version of NPPG. Benefits of renewables to be stressed to locals.
HLP: Due to comments re central belt, seems to be written for wind not offshore or hydro technologies. Recognise difficulty that paragraph must either be general or recognise different locations for technologies.
LP: Considers that inviting development in southern Scotland glosses over carefully considered guidelines in DGC structure plan.
MEGA: Renewables limited locationally due to grid constraints, and this according to Fig 2 is where most of the potential for wind energy arises.
NP: Mention of grid constraints to be removed entirely - changes in trading arrangements may make comment superfluous in 12 months.
NWP: Apparent grid constraints will not prove a real issue when an independent system operator is established. Economic considerations, which can change over the life of the NPPG, should not be planning considerations. Concerned if these issues were to be used by an authority or an objector to justify taking a position on a proposal.
NSW: Urge SE to ensure grid has capacity to support development of renewables in the north and east of Scotland.
PR: Suggests third paragraph reads, "While development can be accommodated to the north, it is expected that the grid, in advance of upgrading and additional capacity, will be able to accommodate significant numbers of larger renewable energy developments more easily in and close to the central belt and southern Scotland" - prevents undue suggestion that proposals outside central and southern Scotland given precedence.
RA: Favour development of 2 or 3 very large wind farms of 150 - 200 MW each on vacant or derelict land or marginal farmland.
RICS: Para 14-16 If locational guidance is to remain - SE should ensure that guidance is updated in relation to grid capacity.
RSPB: Para 14 - 16 Should go further and require provision for 2 or 3 very large wind farms of 150-200MW each. Located in the central belt on vacant or derelict land, within the urban envelope or on farmland, within existing grid constraints and with easy access to existing infrastructure, these developments could significantly reduce pressure on other, more environmentally sensitive parts of Scotland.
RTJ: Upgrading of grid capacity should be undertaken to prevent the south of Scotland being disadvantaged. Wind farms are industrial developments when in certain circumstances can be visually intrusive.
SLF: English and Irish interconnectors can make Scotland a major player in the European energy market.
Savings in transmission losses by encouraging energy to be fed into the grid in the north and west. Should pro-actively seek to upgrade grid.
SNH: Para 14 - 16 Do not think should guide development to the central belt. Grid developed for the most favourable scenario for generation.
SRF: Inappropriate to link planning guidelines to any constraints within the electricity grid system.
SSE: Welcome recognition of transmission issues.
SWLG: Happy for developments being south of Clyde-Dundee line and support developments being close to urban sites.
BWEA: Not confidant that work carried out by the Network Study Group will provide sufficient clarity re constraints to be of much use to this revision - not expect to be useful study.
To forward copy of report re identification of potential contribution of regions to 2010 targets - Scotland seen as one region - may be merit in using similar methodology to identify sub-national targets. Would welcome dialogue with SE and LAs on this matter.
FC: Also Para 33. Updated ETSU reports required ASAP. Will it be full review or just relate to network capacity? Investment in grid and new technologies important.
FCom: Strategic review of grid should take into account improvements that would enable renewable developments put forward by different operators, but in the same geographic area, to proceed.
HC: Presumes final NPPG will take into account updated 1993 study.
HLP: Key is how upgrading to be paid for.
NWP: Aware of these parallel studies on grid constraints, undertaken both by SE and Ofgem. Whilst initial work will be completed by summer 2000 the issues will continue to develop and change with technology and grid investment.
RA: Upgrading of network capacity to focus on that necessary for the exploitation of offshore potential.
SRF: Given the changes taking place in the Scottish electricity system (new electricity trading arrangements) over the next 1-2 years and likely changes in other market forces as well as technology development, the conclusion of the grid review is unlikely to lead to a definitive answer in terms of grid constraints on development.
BBS: SE should make a commitment to improving the grid system.
BWEA: See SRF comments.
CKT: See contradictions between this and Para 38 on location of wind farms. Happy with wind farms on brownfield sites but not in a rural setting.
DMJ: See SLF comments.
ERC: Education by SE and Renewables industry will be needed as expect objections to wind farms in central belt.
FR: Overriding factor is resource availability and practical means of its conversion.
GCC: Benefits of locating new generation capacity in the central belt is accepted
HE: Suggests adding, "smaller developments may not face these constraints".
HIE: Very concerned re grid constraints in the north of Scotland and inferences made in NPPG. Considers draft effectively rules out renewables in their area and excludes them from the economic benefits of the resource exploitation.
Strategic review of the future of renewables needed and would consider future of conventional and nuclear plants and how may be replaced. Require view beyond 2010 and may conclude renewables in the Highlands essential. In these circumstances, appropriate to issue guidance for a short-term target.
NPPG should make it clear that even with a limited upgrade development in northern Scotland is feasible.
LP: Supports promotion of developments in the central belt
MEGA: If committed to renewables, SE should start by improving grid capacity from north to south
NWP: Support location of generation capacity close to demand, whilst recognising the difficulties that this may cause for wind development, both because the resource tends to be smaller and the pattern of settlement more concentrated.
RA: Presumption in favour of local development for local needs, or at least regional development for regional needs.
RIAS: Also Para 20 - Provision for the protection of listed buildings or those in conservation areas needed
RTPI: No interpretation re implication on the greater focus of attention on southern Scotland.
SLF: Most potential renewable sources outwith the central belt - however the road system in the central belt may be a constraint on the transportation of raw materials - need to update transportation system.
SNH: Overlooks fact that new renewables may supply England or Ireland. Suggests:
Insert in Line 2 "or interconnector lines".
Replace last eight words in Line 4. "interconnectors with England and N Ireland or the central belt or some large population centres".
SRF: Wrong to indicate that grid capacity is such a significant constraining issue that it might influence planning policy.
WJM: Too much concentration on grid capacity. Important that guidelines are not seen as being importa
Policy Guidelines : General Principles
ACC: Also Para 61, 70, 72 More guidance on dealing with public perception would be helpful, particularly in relation to wind farms and Waste-to-Energy plants.
BWEA: Agree with comments re poor rate of approval. Possibly due to novel development. Experience of operating wind farms to be put in PAN.
CG: Fault not with planning system but with developers who have no experience of what is acceptable. Clear statement of what is and is not acceptable needed.
DGC: Welcome degree of environmental scoping in the new SRO. Refers to MOD objections to wind farm at Portpatrick.
DMJ: See SLF comments.
ELC: Erroneous belief that existing guidance has placed unnecessary obstacles in the way of renewables - error has led to guidance that has given presumption to renewables development not available to other types of development.
HA: "no single reason" - untrue propaganda and should be removed. Common factor is developers chose the wrong sites. Comments could be seen as SE unwillingness to act fairly.
HC: More analysis required. SE should take note of its own Reporter's decision re three proposed wind farms near Helmsdale. Should also evaluate reasons for hydro schemes being refused. (more info available in response).
Argue only reasonable due to complexity that achieve less planning success - may be better to compare with those developments requiring EIA.
Not reasonable to base any significant relaxation of planning system on planning performance of contracts under SRO
HLP: To give full picture, what is rate for hydro and other schemes?
JD: Does not consider percentage of planning applications for renewables is significant, SRO and Utilities Bill mechanism more likely to have had an impact.
KGB: Revision approached from a false premise as planning applications generally considered with knowledge of local considerations. New obligation arrangements working with 1994 NPPG would result in a more balanced situation as developers able to consider sites other than the most exposed hilltops.
MCS: Comments on Shieldaig scheme and suggests SROs should have environmental sensitivity as a part of initial investigation.
MEGA: Wind farms can never make a significant contribution to the electricity supply. Due to the contentious nature of wind farms - refusal may be justified in sensitive locations.
MoC: No analysis of statistics to demonstrate whether is a real concern or whether planning system working properly in protecting environment.
NWP: May be no single factor, however effect on local amenity frequently raised - lack of definition makes it difficult for developers to propose mitigating measures.
PR: Amend final sentence to make clear all renewable developments experience difficulties. "There is no single identifiable factor behind the lower rate of approval for renewable energy projects in general."
RA: Answer not to reduce planning guidance but guide developers towards appropriate sites.
RICS: Detailed analysis required to ascertain why rejected.
RSPB: Does the figure of 90% approval for all applications include all householder applications? If so the figure is misleading and should be sub-divided to reflect non-householder application success rates and would give a more accurate basis for comparison.
RTPI: Serves to raise following questions:
- Past performance of planning system in renewable as much down to the relatively constrained guidance of existing NPPG as to the policy-making and decision-making of planning authorities.
- The figure of 90% for all applications approved, contrasted with the 85% renewable energy developments, includes householder applications which can hardly be compared with the complexity of issues raised by renewable energy developments.
- If "there is no single identifiable factor behind the lower rate of approval for renewable energy projects", there is no need to highlight the role of planning when major constraints on renewable energy developments exist under the SRO scheme itself, e.g. the output ceiling, the cost yardsticks and the lack of flexibility in the consents.
RTS: Record of planning consents not unreasonable - sees no need to bias planning system towards developers. "significant detriment" is only likely to be demonstrated after installation. Planning system should protect environment.
SCF: Should include brief details of the wave schemes to date.
SLF: Disguises real facts that there are a number of constraints.
SNH: Good success rate for new type of development - going through a learning process on how best to judge renewables.
Approval rates likely to go up as SRO comes to an end.
SRF: All renewable energy projects experience similar problems in that they represent novel developments for which both the public and planners have little or no prior experience.
VJ: Insensitive choice of sites been the main factor re objections.
WJM: Reasons may relate to how SRO set up and leading to developers going to the windiest, and most controversial, spots.
ARIS: 5 TH BP - Replace "areas and structures of built heritage" with "sites, monuments, structures and areas of cultural heritage".
BBS: SE to ensure LAs have access to adequate resources and expertise. Commitment by SE to a more proactive attitude in relation to reviewing development plans should be made clear in the NPPG.
BWEA: Welcome the provisions being made within the first three bullet points.
4 th & 5 th BP References to location should be removed and the focus of these points should only be on design of development. Will avoid inference that there should be a prohibition on development within such designated areas.
The environmental benefit and financial costs of mitigation needs to be balanced and this suggests that reduction of environmental impact is an over-riding factor to be achieved at any cost. The end of each bullet point might be modified to say:
"...ensuring that the design of approved development results in acceptable environmental impact, taking into account the positive benefits of clean energy generation".
6 th BP - minimisation of impacts on communities should be more clearly defined and separated from "early restoration" of sites.
CC: Also Para 19 - Extend to include sites/species of local importance. Take cognisance of the findings of the LBAP when assessing developments. Need to consider local landscape designations such as Area of Great Landscape Value in the Ochil Hills.
CG: Does not consider tourism or employment consequences of renewables. Preservation of "designated areas" does not meet requirement to preserve natural beauty of the countryside which is important to tourism.
Due to type of development all that can be achieved is cosmetic landscaping. Permanent damage not acceptable - work must be prohibited
DCC: Consider will be difficult to "provide...in Structure and Local plans" in locational terms.
DGC: Does not appear to expand on how LAs should ensure that weight is given to national and international climate change commitments and obligations in dealing with individual planning applications. This could be undertaken as part of the SRO process.
Define "site with potential." Suggested only those sites which have planning permission could be considered without causing blight to the site or surrounding area.
Advice on phrase "provide positively" should be considered, believe may be used by developers to further argument that renewables should not be subject to normal development principles.
EAC: Have used criteria based approach based on 1994 NPPG - consider still valid within the terms of this document.
FC: Should include regionally important sites and species designated in LBAP and development plans, other resources include AGLV's, archaeological sites and monuments etc and recognized as important environmental resources.
FCom: Para 18 - 25 LA should be encouraged to consider rural development and employment aspects of proposals for renewables very carefully when considering planning applications for installations.
GCC: Inherent problems associated with the "preferred areas approach". Industry is of the opinion that no benefit is gained if a site is within a preferred area as the environmental impacts still have to be assessed on a site specific basis. Consideration should, therefore, be given to a more "criteria led approach", which would address environmental, technical and social issues.
GCV: Need for system to balance local, regional and national priorities to be set out in the guidance.
GHS: Concerned that although wind farms are rarely proposed in the core of designated areas - can have an impact by adversely affecting their wider setting.
HA: Government entered into commitments without fully understanding implications.
HC: 2 nd BP - later sections must address the relative weights to attach to climate change policies and local, national and international planning considerations.
3 rd BP - site safeguarding unnecessary.
4 th and 5 th BPs - ignore potentially important considerations such as landscape, wild land and fisheries.
Need to promote local benefits as must compensate local disbenefits.
HE: Welcomes Paras 18-22. Asks if certain renewables could be deemed as permitted development.
HLP: 4 th BP What is "inappropriate development"?
LEC: 3 rd BP highlight the need for greater scrutiny by Councils on other permitted developments such as electromagnetic communication links in their potential to sterilise wind energy resource.
MEGA: Safeguarding of sites in former mining areas could sterilise restoration proposals - safeguarding only when has specific reason.
MC: Consideration given to reinstating provision for LA to assess impact on locally important areas.
MoC: Takes no account of regional and local natural and built heritage assets and is contrary to Para 25 of approved NPPG.
NLC: Concerned that guidance is contrary to existing and developing development plan policies. Encourage weight to be given to local environmental concerns.
NWP: Support insertion of a new bullet point providing that the planning system should aim to facilitate...by: 'preparing Interim Development Control Statements in the absence of up-to-date Local Plans or where the time-scale for the review of Development Plans is likely to be lengthy or unpredictable;' Note that advocated in NPPG1.
PR: Carefully considered identification of sites by an LA can provide useful guide for developers. Therefore amend bullet points as follows:
- 1 st BP ".......renewable energy developments in Structure and Local Plans including preferred areas of search;
- 4 th BP ".....and ensuring that the location and design of approved developments minimises in such areas limits environmental impact, and
- 5 th BP "protecting designated geographical areas......"
"Minimise" does not reflect assessment and balance of benefits and costs - suggests "limitation".
RA: Amend 2 nd sentence "....positive provision for appropriate developments." Accepts the need for the first three bullet points to encourage the development of renewables. However, the following bullet points in this section and section 19 do not provide the necessary balance or locational guidance to ensure that development is guided to appropriate sites. The criteria identified are neither comprehensive or precise and require strengthening and clarification.
Propose the following locational strategy:
A strategic national siting strategy which guides development away from areas which are nationally important for landscape, recreation, species or habitat; towards the locations and technologies most easily accommodated within Scotland without adverse impact; and which takes account of the cumulative impact of development. This strategy would aid local authorities with locational issues in the development of strategic local siting plans which national government could correlate, co-ordinate and remove inconsistencies. These would be built into structure and local plans in consultation with local communities and provide guidance to developers on appropriate sites for development. The national siting strategy would consist of three principal guiding criteria:
1.A study of the carrying capacity of different areas of Scotland for different types of renewable energy development. An example would be the study currently being improved by SNH which evaluates issues of landform, landscape scale, pattern and complexity, extent of settlement, and whether or not it is valued for its wild, undeveloped, or unusual characteristics.
2.The clear identification of areas where there should be a presumption against some forms of renewable energy development such as wind energy and hydro which allows for exception for small scale developments to meet local demand. These areas would include National Parks and National and Regional Scenic Areas where development is incompatible with the aims of the designation, and adjacent land where developments would be visible from within the designated area.
3.A presumption in favour of developments which meet local or regional demand: to confront society with the consequences of its own energy use, relate the scale of development to population within an area, increase the likelihood that communities benefit from development through community initiatives and realise the benefits of embedded generation (smaller transmission losses and distribution costs).
Strategically planned approach is required to guide different renewable energy technologies to those areas best.
RC: Early restoration may be difficult to enforce as producer may have no further interest in site when site ceases to operate. SE to consider action when LAs been unable to achieve desired site restoration.
RIAS: Also Para 19 - Questions whether provisions to protect built heritage is sufficient.
RICS: Para 18-22 Concerns on amenity need to be addressed.
RJ: Consents should be subject to a total restoration condition including repayment of public finds when discontinue operation.
RSPB: 1 st BP Encourage planning authorities to produce subject plans for renewable energy projects, particularly in areas where demand, and therefore impacts, may be particularly high.
4 th BP: Welcome and support the aim of protecting designated areas, species and habitats. The existence of designated areas, sensitive or historic landscapes could all be used as effective means of identifying inappropriate areas for specific types of renewable developments.
RTPI: Add 4 th BP to outline what already achieved to make renewables acceptable through negotiations, planning agreements and mitigation.
1 st BP concerned limited designations for protection including the built heritage.
SCA: Concerned does not reflect the value of "wild land" as noted in NPPG 14.
SEPA: Concerned does not fit well with NPPG13 and 14 which require the planning system to take into account the "wider natural heritage". Considers give impression that only nationally/internationally important sites are important - clearly not the case and wording should reflect this by including reference to LBAPs.
2 nd BP add "and where appropriate to the National Waste Strategy" after the word "obligations".
SLC: Also Para 19 - Considered about use of the word "significant" being open to interpretation - clarification needed. Current wording should be kept.
At odds with guidance in Para 36 which looks to a cautious approach and in relation to tourism in Para 30.
SNH: 4 th BP Inconsistent with NPPG 14 - should also take into account local resources. Literal reading of first sentence excludes sites other than Natura 2000 sites.
Should read "Not compromising the objectives of designation and the overall integrity of designated areas, taking care to avoid harm to protected species or habitats, providing for the conservation of biodiversity and the protection and enhancement of the natural heritage audits amenity outwith designated areas, and ensuring that the location and design of approved developments minimises environmental impact"
Guiding principles should include important recreation and amenity interests
SRF: 4 th & 5 th BP - References to location should be removed and the focus of these points should only be on design of development. "minimisation" not be only goal - aim should be to achieve acceptable environmental impacts.
6 th BP - Minimisation of impacts on communities more clearly defined and separated from the need for "early restoration" of sites.
SS: See also Para 19 - consider need reference to schemes taking account adjacent land and water use. Does not wish to see land and water currently used for sport to become unsuitable due to development. SE view on when recreational resource is justified would be welcomed and incorporated into guidance on development plans and control sections.
WDC: 2 nd BP - suggests that due regard should be made to the Development Plan in addition to national and international climate change policy. This is particularly relevant given the advice contained within Section 25 of the TCP(S) A 1997.
WTS: Important development undertaken sympathetically and environmental harm kept to a minimum.
ACC: Consider reinstating statement or a similar statement from previous guidance on green belt. Further guidance or clarification on distance and quality of life would be required to assess this. See also Para 36.
AHSS: Do not accept "significantly detrimental" - should be removed as designated areas should have a presumption of protection.
ARIS: 3 rd BP 'Interfere' should be replaced with either 'adversely effect' or 'impact'. Again a list of what this term means should be included. It should also refer to both NPPG5 and NPPG18. As with the natural heritage it should list examples e.g. World Heritage Sites, listed buildings, Scheduled Ancient Monuments.
BBS: Paragraph goes too far and is in conflict with section 25 of the TPC(S)A 1997.
BWEA: Strongly welcome positive provision made for presumption in favour of development for renewable energy and for not automatically ruling out development within protected areas.
Within many designated areas it is likely that development can be accommodated without causing adverse impact to the integrity of the habitats or species for which the original designation was made.
2 nd BP should state: "have a significant adverse effect on those features, species or habitats for which sites have been designated for the protection of species and habitats of international and national importance i.e. SSSIs, SPAs, SACs and Ramsar sites. Outwith these designated areas it must be demonstrated that there is no significant adverse impact upon internationally or nationally protected species or habitats (see also NPPG14: Natural Heritage);"
3 rd BP not clearly state by which method an area or structure has been identified and the word "interfere" can be interpreted in many different ways. Suggest should be amended to state "have a significant adverse impact on areas or structures designated for the protection of their built heritage value".
Statement "quality of life" vague and open to differing interpretation.
It should be made clear, within the last sentence, that the advice within paragraphs 32 - 64 supplement the overall policy within Para 19 and does not replace it. Indeed, this sentence might be removed from the guidelines.
CEC: Although in line with structure plan policies - consider places insufficient emphasis on the need to protect the landscape setting of urban areas i.e. greenbelts, regional parks and AGLVs - SE to provide more guidance on impact of renewables and there assessment in these circumstances - looking to new PAN 45.
CG: Refers to DGC structure plan - Policy 22 on renewables approved by SE in December 1999. Considers there to be complete change in policy since December. Policies show complete disregard to local interests.
CNES: No comment on transmission lines or grid development proposals.
Guidance makes clear no blanket restriction on renewables within designated areas.
4 th BP not make sense, needs more comment on built heritage interests including designations.
No weight for the protection of regionally or locally important sites.
DGC: Particular concern - recommend SE considers including reference to Landscape Character Assessment and to pay more attention to biodiversity. Considers ignores commitment set out in NPPG 14 Para 46 re wider natural heritage.
DMJ: See SLF comments.
EDC: Concerned re regionally significant areas such as the Campsie Hills. Guidance amended to maintain the existing protection of local or regional designations from possible adverse impacts.
ELC: Little protection and scope for LA to control development outside designated national/international areas - Guideline to make clear renewable developments should meet same standards as applied to other types of developments.
FaC: Offers less protection to nationally/ internationally protected areas than is case for other uses i.e. minerals. Approach seems to undervalue the significance of the protected areas.
Undervalues locally important areas as there are fewer nationally designated in the central belt may have previously been degraded but now being restored through projects such as the Central Scotland Forest It would be wrong to dismiss the importance of such areas.
FC: 4 th BP How will "quality of life " be measured - local residents will have strong views on such a term.
3 rd BP "cultural" rather than "built" heritage more helpful to incorporate resources to be protected.
2 nd BP Reference to designated areas should include sites and monuments
Greater emphasis to be given to protection and preservation of archaeological and cultural heritage with reference to: archaeological sites, monuments, structures or areas of international or national importance. This includes World Heritage sites, scheduled ancient monuments, listed buildings, sites in the inventory of historic gardens & designed landscapes. Sites and monuments of national importance in the non-statutory register of monuments should also be included.
GCC: The fact the planning system should encourage renewable development and not put obstacles in its way is seen as compatible with the aims of sustainable development and Local Agenda 21 Strategies.
2 nd BP - in the interests of clarity, the 2 nd sentence should be deleted and replaced as: "Have a significant detrimental effect on species and habitats, listed in the UK BAP as being of international and national importance, outwith the above designations:"
3 rd BP seems to cover all such structures, despite Para 18 referring to structures of international and national importance. For consistency the text should be altered to read as follows: "Interfere significantly with built heritage areas and structures of international or national importance":
4 th BP should be strengthened in terms of defining what would be unacceptable and expanded to include reference to local designations as described in NPPG 14: "Have a significant long term detrimental effect on the quality of life of people living nearby or on local Environmental Designations as identified in adopted Local Plans (in terms of NPPG 14)".
GCV: NPPG to provide LAs with guidance re resources of a local and regional level. SE assertion re grid capacity may have serious impact on environment and landscape resources in the West of Scotland much of which is significant in local and regional terms.
Define "significant impact" - ambiguous, helpful if were to provide greater guidance on what is acceptable level of impact.
GHS: Society wants designed landscapes referred to explicitly in the document with an extra bullet point - "adversely affect the character and setting of sites identified in both the Inventory of Gardens and Designed Landscapes in Scotland (1987) and the extension to the Inventory, as well as other historic gardens and designed landscapes of national or regional significance." Suggest would be in line with advice in Para 29.
HA: Goes against normal rules - quotes New and Renewable Energy from DTI 1999 ". the planning system should not be weighted in favour of renewable energy development". Quality of life for tourists omitted.
HC: Degree of protection for designated areas less than contained in previous NPPG. Is justified in the context of overall SE policy on natural heritage? - must be set against policies set out in NPPG 14 and circular 6/1995. Protection of landscape character required outside designated areas.
2 nd BP at odds with Conservation (Natural Habitats &) Regs (1994).
No comments re landscape and scenic areas of local importance.
Fisheries to be included for hydro projects.
Traffic impact on roads and bridges and access arrangements should be included.
"Quality of life" in last BP too vague - reworded to relate to Para 31.
HLP: 4 th BP How is quality of life defined?
KGB: Approach turns good planning practice on its head - prerogative of LAs to demand reasonable proof that developments will not damage valued planning assets.
DGC structure plan made specific provisions for valued but undesignated areas important for leisure and tourism - should not be undermined by NPPG.
LEC: Statement of general presumption in favour should also emphasise a presumption in favour of new renewables installations in their functionally appropriate sectors of the terrain or landscape.
MCS: Should be the same recognition of wild land in NPPG6 as in Para 16 of NPPG14.
MEGA: SE to define "significant". Where specialist consultees such as SNH, RSPB, HS etc consider that there would be a significant environmental impact - then there should be a presumption against such developments.
MoC: 1 st BP - Development should conform to National Park Plans.
2 nd BP - Significantly contradicts Para 42 of NPPG14.
Approach to protecting "statutory sites contradicts Para 69 of NPPG14.
Vital LA make provision for developments within regionally/locally sensitive areas.
4 th BP - Needs to be widened to include tourism, leisure and working environment with guidance on how "quality of life " is to be defined.
NLC: Re-wording to provide greater control over important landscape and conservation designations and a commitment from SE to offer guidance on the degree of harm accepted.
NWP: Support except for term "quality of life" in last BP - will be subjectively interpreted and used as a reason for refusal.
PR: Use of "designated " in 3 rd BP would allow for official assessment prior to being given protection, therefore "interfere significantly with areas/structures designated for protection due to their built heritage interest".
RDC: Support but consider 4 th BP is difficult to define and may lead to protracted debate.
RIAS: Guidance should ensure factors of scale, location and design of developments allow balance between innovation and protection of the built environment - expects the guidance to seek 1) excellence in design and 2) evidence developers have tried to ensure this.
RC: NPPG 14 and EC Habitats directive refer to assessment being made in relation to regionally and locally important sites. These sites should be allowed to assert strict criteria when assessing renewable proposals.
Lack of guidance re green belt, agricultural land and EIA.
RJHW: Believes that the implication that only nationally and internationally designations could justify refusal to be against spirit of planning system - which should look at each case on its merits within the plan led system.
RM: Principles make assumption that all areas worth preserving are already known yet adequate analysis and statutory protection of potentially important scenic areas and areas contributing to bio-diversity has not been undertaken. 'black and white' legislation.
How can a LA protect local bio-diversity when a planning guideline on renewable energy pre-empts that protection?
4 th BP fails to be "catch all" protection as intended.
Currently licence to ride roughshod over local communities, local planning departments and local democracy. Suggests a compensatory mechanism by improving the way a LA can examine the impact of any scheme using EIA.
RSPB: Appears to be section which establishes key criteria against which planning authorities evaluate proposals. Falls short of being either comprehensive or precise. Recommend further clarification:
1 st BP - Add 'the landscape character and nature conservation interest of National Parks' after 'and'. More accurately reflect the aims and objectives of the recent National Parks (Scotland) Act 2000.
2 nd BP Delete 'have a significant' and all reference to SSSIs, and replace with 'adversely affect the integrity of statutory international sites and Ramsar sites'. Habitats Regulations require competent authorities to evaluate if a proposal will adversely affect the integrity of a site having first considered whether it will have a significant effect. This section creates confusion between these two processes and suggests that to refuse a renewable energy project a planning authority would have to be satisfied that an affect is both significant and adverse. Effective protection of species outwith designated sites has proven to be one of the most difficult aspects of renewable energy development. Therefore, welcome guidance on protected species and habitats outwith protected areas, but recommend the following be added after the last sentence: 'for example, the Birds Directive provides protection for all rare and vulnerable species mentioned in Annex 1 of the Directive and for important concentrations of regularly occurring migratory birds (see also NPPG 14 and revised Circular 6/1995, published June 2000)'. Would clarify why species and habitats need to be protected and guide developers and local authorities to the appropriate guidance documents for further information.
Add a new 3 rd BP: 'adversely affect the conservation objectives and/or reasons for identification and notification or designation of sites of national wildlife importance (this includes indirect effects from outside the site).' The criteria for international and national sites have been separated to clarify the different regulations and tests which apply to them.
4 th BP Concerned that 'a significant detrimental effect on the quality of life of people living nearby' too imprecise - point should either be removed or elaborated upon.
New 5 th BP: Add 'have a significant negative impact on LBAP priority species.' - would again more clearly reflect the hierarchy of protection which planning authorities must consider and which is laid out in NPPG 14.
RTJ: Use of words "significant" and "significantly" will make it possible to ignore objectors.
RTPI: Falls short of being comprehensive. Suggests:
1 st BP Add "the landscape and natural conservation interest of" before "national parks".
2 nd BP Habitats Regulations require competent authorities to evaluate if a proposal will adversely affect the integrity of a site having first considered whether it will have a significant effect. Section creates confusion between these two processes and suggests that to refuse a renewable energy project a planning authority would have to be satisfied that an effect is both significant and adverse. Suggest the first sentence should read "adversely affect the integrity of statutory international sites and Ramsar sites".
Welcome recognition of impacts outwith designated sites and suggest that this should be made a separate bullet point. Recommend adding "for example, the Birds Directive provides protection for all rare and vulnerable species mentioned in Annex 1 of the Directive and for important concentrations of regularly occurring migratory birds (see also NPPG 14 and revised Circular 6/1995 of June 2000)" this would clarify why species and habitats need to be protected and would guide developers and local authorities to the appropriate guidance.
Propose additional bullet point for national sites in view of the different regulations and tests which apply to them. This extra bullet point would read "Adversely affect the conservation objectives and/or reasons for identification and notification or designation of sites of national wildlife importance (this includes indirect effects from outside the site)".
3 rd BP Add "including historic gardens and designed landscapes".
4 th BP very unspecific. Can't rely on Para 31 for clarification and some elaboration of the types of detrimental effect which can be expected should be included.
Additional BP to recognise the importance of locally important natural heritage sites. It should be noted that the bullet point relating to built heritage interest does not discriminate between different levels of importance.
SAC: Concerned provides a four point test - likely to be only basis on which developers promote their proposals. Does not refer to issues of landscape and visual impact. Landscape dismissively referred to in Para 21.
Limited scope of test gives rise to implementation of development plans draft South Ayrshire local plan policy ENV35 which has a general presumption in favour of renewables refers to amenity not referred to in Para 19.
SBC: 4 th BP Recommends re-wording as "quality of life" could be open to many interpretations.
SCA: Same strictures should apply to all landscapes regardless of designation.
SCF: Greater recognition of the landscape value of the coast necessary and would benefit, from reference to principles in NPPG 13 regarding appropriateness of development on the undeveloped and isolated coast.
SLF: Define "significant.....quality of life.."
SNH: Opening phrase interpreted that LA need to demonstrate adverse impact - acceptability of impacts to remain with the developer. Tests for designated areas weaker than NPPG 14.
1 st BP - Protection for National Parks to cover all facets of the natural/cultural heritage. Protection for NSAs more than landscape character.
Needs separate BP relating to areas outwith designation - does not reflect Para 9 - 22 of NPPG 14.
Renewable energy developments should be permitted where they are in accord with the development plan, unless material considerations indicate otherwise.
"Where there is a potential impact on national designations (NSAs, SSSIs, NNRs, National Parks, and Natural Heritage Areas), renewable energy projects should be permitted only where it can be demonstrated that the objectives of designation and the overall integrity of the area will not be compromised unless any significant adverse effects are clearly outweighed by social and economic benefits of national importance. Given the choice of locations currently available for renewables development, climate change benefits should not be regarded as outweighing any significant adverse effects on the qualities for which an area has been designated."
"Where there is a potential impact on international designations (Ramsar, SPA, SAC,) renewable energy projects should only be permitted for which it is demonstrated that they will not have an adverse effect on the conservation interests for which a Natura site has been proposed or designated, unless there is no alternative solution and if there are imperative reasons of over-riding public interest including those of a social or economic nature. Given the choice of locations currently available for renewables development, climate change benefits should not be regarded as establishing an over-riding public interest in any one proposal.
Elsewhere, planning authorities should seek to:
"safeguard and enhance the wider natural heritage beyond the confines of nationally designated areas. The effect of a renewables proposal on the natural heritage should therefore be considered as a material consideration, though the level of protection will not normally be as high as that afforded to sites of national or international importance. In applying policies to local designations, planning authorities should ensure that these are not such as to impose unreasonable restrictions on the ability to meet overall national targets for renewable energy."
"safeguard Scotland's rich diversity of landscapes, including their cultural value and the wild land character of remoter mountain and coastal areas; areas or species identified within Local Biodiversity Action Plans as important for the conservation of biodiversity; and the opportunities for enjoyment of open-air recreational activities in a natural heritage setting.'
SRF: Strongly welcome positive provision.
Wording should ensure that there is no presumption against development within designated areas.
Should be no implication that renewable energy and natural heritage resources are automatically in conflict.
3 rd BP not clear in its use of terms such as "interfere significantly" suggest "have a significant adverse impact upon areas or structures designated for the protection of their built heritage value"
The statement regarding the "quality of life of people living nearby" is too vague and open to differing interpretation.
Make clear that advice within Paras 32 - 64 supplement policy within Para 19 and does not replace it.
SWLG: Also Para 18 - grave concerns that guidance will recommend approval of schemes in wild land outside areas designated in 2 nd BP. Current wording implies that the scenic value of quality non-designated sites with important recreational and tourist activity hardly counts for anything.
WDC: Appears to be no credence given to regional or strategic designations which, although may not be worthy of national recognition, play an important role within the local area. A form of 'sequential test' be considered in relation to the locational framework, in order that the least sensitive areas either in landscape or heritage terms are considered first and thereafter other areas are examined.
WJM: "Quality of life" means many a great many things to different people.
APRS: What is an "unnecessary obstacle"? - such a vague statement not helpful.
May need to use case studies. If plant becomes uneconomic once implemented - will LA have power to enforce decommissioning?
BBS: Level of output to be a planning consideration given potential consequences of a renewable energy development.
BWEA: Do not believe that planning policy should include the reference to modifying the scale of a development - leaves the planning process open to a final debate on whether scheme changed to balance impacts. Do not think this was the intention in drafting NPPG6 and suggest that final sentence end after "planning consideration".
DGC: Welcomes that level of output from a scheme is not a planning consideration. May limit LA ability to consider scheme in relation to national commitments as stated in Para 18.
FaC: Some concern that the output of schemes is not to be weighed against the likely environmental impact.
FCom: Merit in taking account all the costs and benefits: economic, environmental and social; in reaching a decision as to whether a particular scheme is desirable, given that the scheme has met the needs of environmental design guidelines.
FR: Planning system should encourage appropriate development and not place unnecessary obstacles in its way. Welcomes statement re level of output not a planning consideration. Further detail welcomed on second section of last sentence "....relevant environmental factors which lead Councils....".
GCC: may be occasions when amount of renewable energy produced does not justify associated impact on environment.
GCV: Para 20 - 22 Welcomes principle but again considers lacks balance and gives insufficient recognition to the wide range of social, economic and environmental pressures when preparing development plans.
Para 21 is an overstatement in claiming renewables have little impact on the environment.
HC: 1 st sentence tendentious - omitted unless there is concrete evidence of "unnecessary obstacles". SRO scheme expected number of failures.
Last sentence should be omitted as is unhelpful.
LEC: Give examples of "obstacles".
MEGA: The role of the Scottish Ministers is unclear.
RA: Landscape considerations not unnecessary obstacles.
RTPI: "The level of output from a particular scheme should not be a planning consideration" unnecessary. It may well be a material consideration, depending on the circumstances but an understanding of the contribution which any development will make to overall demand is an essential part of the planning process, even if it does not always become a determining issue.
SAC: Presumption in favour of development to be replaced by more balanced approach especially in relation to landscape character and visual impact.
SNH: Open to misinterpretation. Assessment of any scheme will involve the weighing up of benefits (including climate change benefits) on one hand against environmental costs on the other.
'Government's renewable energy targets are expected to be met through the cumulative output of many small developments added to the output of a smaller number of larger developments. Therefore, it may be assumed that a development makes a contribution to this national need regardless of its size. Assessment of the acceptability of environmental impacts associated with a scheme should take into account the scale of climate change benefits associated with the scheme.'
SRF: Do not believe that planning policy should include the reference to modifying the scale of a development.
APRS: Para 21 - 22 taken together are inconsistent. Clarify / review these paragraphs.
BBS: Wind farms will have a dramatic effect on landscape - steps should be taken to educate the public so that wind farms are seen in a positive light. SE should record such a commitment. Comments also refer to Para 30 - developments should be marketed as an attraction and not just being seen as compatible.
CC: Define "appropriate controls".
DGC: Should give reference to national framework of assessments published by SNH.
ELC: Underestimates the impact of development and misleading to say introduction of wind farms is an "incremental change".
FC: Where proposals are linked to the grid, then any best value assessment of the environmental risks / impacts should be able to be weighed against the benefits arising. A small number of projects feeding the grid may well be cumulatively significant, but the same applies to the cumulative environmental impacts.
GCV: Overstatement in claiming renewables has little impact on the environment.
HA: Remove planners jargon. Perhaps written by town dweller who is not aware that the Scottish landscape has not changed for hundreds of years.
HC: Final sentence at odds with experience and possibly with SNH LCAs. Does not reflect Highland landscapes. Appraisal shallow and should be deleted. Developers to carry out an LCA to check whether the landscape can accommodate change.
MEGA: Re environmental concerns - stress that units incinerating industrial waste should be subject to stringent control.
NWP: Suggest add, at the end of this Para, 'In some landscapes the presence of wind turbines may add interest and diversity to the landscape. Single turbines or small groups may serve as landmark features near towns".
PR: Important reminder re incremental change historically taken place.
RA: Wind farms are semi-industrial structures which must be guided towards appropriate sites, in appropriate numbers and be determined by the extent of local demand which will reflect the general make-up of the area.
RC: Arguable - developers can have a significant impact especially in rural areas - impact increased with additional infrastructure required. Can potentially "open up" areas. Need balance between economic benefits, impact and contribution can make to supply of renewables.
RICS: Welcomes positive statements
RTPI: Would be content with last sentence were there clearer locational guidance for the national interest. In the absence of such guidance, concern that every tract of undesignated landscape can expect to have its token wind farm.
RTS: Not reasonable to expect wind farms not to have a "significant adverse effect." Supports use of central belt for wind farms.
SAC: Landscape dismisively referred to.
SCA: Impact in rural areas very large with two risks 1) little local consultation and 2) large population outwith the area may have an interest but little opportunity to comment.
SLC: Qualification needed by advising on what is a suitably located urban area. Emphasised as Para 31 states that development can raise concerns amongst local residents. Care needed to ensure amenity.
SNH: Last sentence misleading. Does not follow from the fact that most landscapes have been subject to incremental change that they can therefore accept renewables developments.
"'Most landscapes in Scotland have been subject to incremental change over many years. Many of these landscapes should be able to accommodate renewable energy developments if these are in appropriate locations and of an appropriate scale and type.'
SWLG: The siting of a wind farm with 30 - 70 metre towers and large rotor blade diameters hardly an 'incremental change' to a locality. Most landscapes not able to accommodate such development. Most incremental change is through crops/vegetation/trees at the field / hillside level from 0-30 feet level, not something 3 to 7 times taller. The last sentence implies that with some controls, renewable energy projects can fit in anywhere easily. Gives great concern.
BWEA: Supports proposal that renewable energy projects be acceptable uses in urban areas. Like to be assured that the intention within this clause and the preceding one is not to imply that there is a requirement that urban sites should be developed before rural ones. (Note that this approach has been adopted with other types of development such as housing and retail developments).
CC: Asks how renewable energy brings specific opportunities to brownfield /semi-rural sites. Opportunities for environmental enhancement of degraded sites should be considered as part of renewables development.
CSCT: Supportive of idea - wish NPPG to specifically mention the potential for the development of biomass as a renewable source based around derelict land in the Central Scotland Forest - feel has sufficient strategic importance to justify mention.
DMJ: See SLF comments.
FaC: Phrase concerning use of brownfield sites considered too general and sweeping. Theme continued in Para 55 - 63 where major public concerns likely to be raised. Amenity of communities in urban areas must be recognized as a prime consideration.
FCom: Agree that brownfield sites might be naturally attractive for some forms of development as likely to be close to grid. In respect of wind energy, may be benefit in considering forest sites, because:
- Roading (at least within the forest) will often already exist, enabling shared use, and minimising additional expense and environmental damage;
- Forests (with the use of forest design techniques) can be used to mitigate the visual impact of developments and to reduce any harsh edges that would otherwise be evident;
And in the Forestry Commission estate, because, in addition:
- Many of the national forests are located in relatively windy areas;
- Although the sensitivities will vary in each case, much of the Forestry Commission estate is of a nature and scale that renders it relatively robust, and more readily able to absorb developments without undue damage to the natural heritage; and
- The Forestry Commission forests are owned by the Executive, and therefore (like other such land) provide an opportunity for the Executive to lead by example.
GCC: Welcomes presumption in favour of renewables in urban brownfield sites.
MCS: Generally supportive.
MEGA: Suggests this should not be used as a way of delaying restoration of open cast voids and allowing landfill for energy purposes - which is something they are against. Suggests some voids should be left for industrial archaeology.
MC: Gives little explanation of how the use of sites in urban areas can be achieved without unacceptable impact on amenity. Whilst semi-rural locations may be acceptable sites for renewable, urban location is questionable.
MoC: Approach too simplistic and does not recognise the range of renewable developments - certain types not appropriate for urban sites and quality of life issues will be important considerations.
NSW: Potential for co-operation by the energy sector with site operators should also be highlighted.
RA: Presumption in favour of such developments will not alone be sufficient to guide development towards these areas while the market dominates siting strategies. Local production for local needs would be much more effective, as would financial incentives to develop in such areas.
RICS: Concerned locational guidance could hinder developments. Use of brownfield sites may be in populated areas and promote amenity problems. Developments market driven and left for LA and developer to identify locations on a regional basis.
RSPB: Strongly supports.
RTJ: Sensible use of land.
RTPI: Welcome the emphasis on scope for renewable energy developments in urban areas.
SLF: Caution required re the disposal of waste materials.
SNH: Blanket statement which pays little regard to the need for good practice in design and location of new industrial structures in and around settlements. Rather than establish a presumption in favour of renewable energy development, recommends guidance should invite planning authorities to incorporate climate change benefits in their consideration of the use of brownfield land.
SS: Opportunity for access and formal sports facilities should be considered e.g. foot and cycle path provision through a wind farm.
SWLG: Agree wholeheartedly.
WM: "presumption in favour" removed - Deliberately excludes undesignated areas.
MEGA: If wind farms to be regulated less from the centre - more technical guidance required for councils.
RA: Asks for quotas of new renewable energy production to come from different technologies Provide more complete information on the locational requirements and potential impacts of wave, tidal and offshore schemes.
RM: Why this presumption in favour of wind-power again - because the wind-power lobby is vociferous or because energy policy is just out of date?
A better phrasing would be,
" 23. While there has been focus on wind energy as an important source of renewable energy, development plan policies should recognise the full range of renewable energy sources, their differing characteristics, locational requirements and the potential for exploiting them within appropriate environmental safeguards."
RSPB: Will be difficult while the NPPG and PAN do not contain more complete information on the locational requirements and potential impacts of wave, tidal and offshore schemes.
RTPI: Agree development plan policies should recognise a full range of renewable energy sources, concerned at lack of guidance on the whole range of options for offshore developments which will also have onshore implications under the planning regime.
APRS: Inexperience of LA and may need case studies. PAN 58 makes good use of them. SE should be advising on additional useful information sources.
BWEA: 1 st sentence leaves open to an authority to create unacceptable planning policies without justification (e.g. "impacts could be minimised by only siting turbines in groups of less than 4 turbines..."
2 nd sentence to end at the word "inappropriate". It would not be possible, within the resources of a local authority, to consider every type of development proposal that might come forward and thereby develop full justification for a blanket objection. Danger that such a statement may still allow planning authorities to introduce policies that place severe constraints upon development and would prefer to see the sentence expanded to include "policies that rule out the development or place fundamental constraints..."
HC: Final sentence fails to give weight to local concerns - not be helpful in a local context to appease objectors. NPPG should encourage developers to maximise local economic and social benefits.
HLP: "significant" should not be used - may be clearer to use "material consideration." see Para 72.
PR: Worried policies may be worded to place severe constraints upon or prevent development - suggests " Planning policies that either directly rule out or place fundamental constraints upon development of all or specific types of renewable energy technologies will be inappropriate. Where specific technologies are judged inappropriate, sufficient justification must be given."
RA: EIS for every development. Planning policies should follow the above siting strategy and indicate the degree, location and type of development within their local authority area.
RICS: Welcomes recognition of the wider economic benefits.
RSPB: Should also seek to contribute towards the objectives and targets contained in LBAPs and/or the UK BAP. This should include areas identified as being able to make a positive contribution to meeting targets through, for example, re-creation/re-establishment schemes, and links, corridors and stepping stones required under Regulation 37 of The Conservation (Natural Habitats, &c) Regulations 1994 (Habitats Regulations).
RTPI: Suggest planning policies should also give guidance with regard to specific contributions which developments could make towards local environmental and economic benefits. In the last sentence, where mitigation and compensation in the local environment is satisfactory, the wider environmental and economic benefits of renewable developments become of overriding significance and not merely "a significant consideration."
RTS: Wider economic and environmental effects are more likely to be adverse as these are areas dependent on tourism.
SRF: Focus should be on reducing impacts to an acceptable level. Not clear how a policy can give robust guidance that would be suitable to a wide range of types of project. 2 nd sentence end at the word "inappropriate".
WDC: Given wide range of renewable energy types, difficult for planning policies to guide developers on how to minimise the impact of proposed developments. Whilst planning policies can suggest a range of issues that should be taken into consideration in assessing the impact of developments it would perhaps be appropriate for the PAN to contain supplementary guidance to assist developers and the LA.
BWEA: Add "Such economic benefit should be taken into account in reaching planning decisions".
DMJ: See SLF comments.
HE: Link between renewables and rural development is welcomed. 2 nd sentence is only relevant to wind farms - not biomass as jobs are permanent. Suggests remove phrase "particularly during the operational period".
MEGA: Jobs to be weighed up against environmental costs and effects on tourism.
NWP: Would support strengthening of paragraph and the insertion of 'although the construction phase of a development may occur over a short period the economic benefits may be locally significant'.
RA: RA policy would present a balanced spread of jobs across the country.
RTPI: Should be made clear that the last sentence deals with benefits which will be remote from the development sites, and probably in urban areas.
RTS: Jobs in operational stage are minimal - idea that rural economies will be revived is illusory.
SLF: Downstream effect on the manufacture and development of equipment.
SNH: Manufacturing activity is unlikely to be local in most circumstances, unless the scale of development in one area is sufficient to warrant a manufacturing base.
Suggests: A mature Scottish market for renewable energy technology has the potential to establish and support manufacturing activity and offer export potential. Contributions to the local economy and local employment are likely to be mainly for construction and plant operation, though some manufacturing capacity may be developed locally where the scale of development is significant.
SRF: Without clear definition inappropriate to indicate that renewable developments do not give rise to significant permanent jobs.
SWLG: In weighing up employment benefits, should also take into account loss of jobs from tourism etc.
FR: Typo "fails" not "falls" in 2 nd sentence.
GCC: Also Para 27 Use of EIA should be encouraged. Even if a formal EIA is not required, the evaluation process may highlight environmental issues which need to be addressed.
HC: Quote thresholds for screening opinions under EIA Regs.
MEGA: Suggests EIA criteria are repeated for clarification.
NWP: Also Para 27 proper scoping required.
RA: All proposals statutorily supported by an EIS. Mitigation measures should be identified within the statement, and there should be a requirement to implement these measures. Monitoring of the actual impacts during construction, while the development is operative and after it has been decommissioned should also be a duty on developers to inform future development. All EIS audited to ensure neutrality.
RM: Principle reason for the imbalance which arises from the draft NPPG6 is the way in which EIAs are constructed and used. If greater power is to be given to developers there must be a counter balance somewhere. This could well be in being more prescriptive about the rules governing the EIA.
Local authorities need to be helped to properly assess potential ecological and scenic damage to an area. There must be stronger guidance to authorities on what they can demand in an EIA. The proposed changes provide massive economic opportunities for developers - not unreasonable that they pay some price for that.
RSPB: Also Para 27 Should make clear that under the Habitats Regulations and as identified in revised Circular 6/1995 competent authorities may be required to carry out an Appropriate Assessment of any proposal which could have a significant effect on a European site.
SNH: EIA process needs to be able to consider all aspects of the development, even if these come forward later or under a different planning application.
SWLG: Most if not all renewable projects to require EIA.
BWEA: LA and developer to agree the scope of such an EIA.
PR: Addition to first sentence may be beneficial "Planning authorities and developers should consider at an early stage whether EIA should be undertaken and the scope of such assessment".
RA: Facilitates effective site selection and ensure that best practice standards are adopted and would be important in keeping the local community fully informed of the possible environmental impacts of any development.
RTPI: Should emphasise the importance of scoping for EIA. In addition, actual thresholds should be stated here. Reference should be made to revised Circular 6/1995 (June 2000) with regard to the requirement under the Habitats Regulations that competent authorities may be required to carry out an Appropriate Assessment of any proposal which could have a significant effect on a European designated wildlife site.
nt only in southern Scotland.
AHSS: Needs more than reference to NPPG 18 - separate section required to give broad consideration to the impact on the cultural environment both designated and undesignated. Guideline must warn against the damage of sites.
BWEA: See SRF comments.
ERC: Does not consider that the issue of development in the green belt is adequately considered, as guidance is weaker than in previous NPPG. Such issues should be afforded with "open and thorough consideration."
FCom: Proposals should take into account the local authority's Indicative Forestry Strategy, where appropriate.
NWP: Conflicting advice undermined by inquiries. Important dovetail and where conflict primacy established.
PR: Include paragraph in locational considerations to explain characteristic siting requirements of various types of renewables.
RSPB: Should include mention of amended circular 6/1995.
RTPI: General heading "Locational Considerations" is misleading. The locational criteria of guidance do not result in any better concept of location. It is only when the criteria are applied in statutory development plans that locational concepts become clear. Suggest that the heading should be "Planning Policy Guidance". Also suggest preceded by a sub heading "Related Planning Policy Guidance" Addition to the list of guidance referred to as follows:-
- Habitats Directive Circular 6/1995 (as revised June 2000).
SNH: List of relevant national planning policy guidance should include NPPG 11 on Sport, Physical Recreation and Open Space, and the Revised Guidance Updating Scottish Office Circular No. 6/95 in relation to Natura 2000.
SRF: Where different planning guidelines give conflicting advice, there needs to be a clear policy framework to avoid ambiguity.
BWEA: Clear guidance that NPPG6 is consistent with and takes into account the other NPPGs. NPPG6 should take preference.
3 rd sentence introduces ambiguity by the use of "potential for affecting..." as this may give rise to differences of opinion over the concept of "potential". Suggest "the potential for" are removed and the sentence reworded to:
"..development proposals should avoid significant adverse impacts on the character...".
"siting" in the final sentence may be unclear - believe the intention here was not to indicate location but positions within a site and so the sentence should be expanded to:
"..careful and sensitive micro-siting and design..."
DGC: Level of attention given to these issues should be expressly dealt with alongside that of designated areas.
GCC: Thrust/context of Para 29 is actually dealing with matters that need to be included in section on "guiding principles" and should be incorporated into Paras 18 to 22 This needs to be done not only because these matters should be covered by such principles, but also to provide a context for the proposed amendments to paragraph 19.
GCV: Rephrase - LAs look to NPPG1 to interpret sustainable development directives and to provide guidance that development and conservation are not mutually exclusive objectives.
HC: Paragraph unclear - each NPPG should be written to uphold the other.
Fails to pay regard to valued landscapes such as wild land. No mention of fisheries.
LEC: 2 nd sentence: '...integrity of a designated resource.' Should it be spelt out this refers only to nationally or internationally designated resource?
MEGA: Renewables only environmentally sound when SE will reduce reliance on fossil fuels.
NWP: 2 nd sentence prefer 'development proposals should avoid significant adverse effect on the character, quality and integrity of a designated resource.'
PR: Change 3 rd sentence to avoid ""perceived effects" and focus upon "actual effects" and remove "the potential for effecting" and thus reads " Policies in the latter group do not necessarily preclude renewable energy developments, but development proposals should avoid significantly affecting the character, quality and the integrity of a designated resource."
RA: Define "significant effect."
RJHW: Do not consider that this paragraph is an adequate substitute for Para 39 in existing guidance - therefore believe that this paragraph should be re-instated in a suitable form.
RSPB: Welcome reference to LBAPs in this section but believe that the recommended changes given above would provide more specific guidance to planning authorities while ensuring that the targets and objectives of LBAPs are considered at the appropriate stage.
RTPI: Suggest that advice on the preparation of LBAPs from SNH should specifically refer to the promotion of sustainable renewable energy.
SNH: Environmental soundness' is a new NPPG phrase - seems odd that it is introduced here.
Questions if remainder of paragraph adds over and above what is said (or should be said) earlier. Preference to ensure that this material, and in particular the references to environmental assets and local biodiversity plans, is incorporated within the 'guiding principles' section. Although last sentence is correct that careful and sensitive siting and design of renewable energy developments can reduce impacts, it is important to stress that siting and design cannot reduce impacts to an acceptable level if the location is not appropriate for a particular development.
SRF: Clear guidance that NPPG6 is consistent with the other NPPGs and therefore that NPPG6 is the primary guidance relating to renewable energy schemes.
3 rd sentence introduces ambiguity in the phrase "potential for affecting" - suggest words removed. Development proposals should avoid "significant adverse impacts" rather than just "affecting significantly" as stated.
BBS: Developments should be marketed as an
attraction and not just being seen as compatible.
BWEA: Would like to see comments re tourism strengthened as do not believe there is any evidence that renewable energy projects impact adversely upon tourism and recreational activities during their operation.
3 rd sentence - note there appears to be a presumption that visual impacts are adverse and that they require to be minimised. Believe this sentence could be removed without changing the intention within the clause.
CKT: If developing tourist industry in southern Scotland to be given a chance, no wind farms. Para 30 very subjective and disregards views of a number of countryside bodies.
CT: Tourist potential of wind farms doubtful.
EAC: Supported through local plans as seek to favour sustainable tourism.
ELC: It is at best arguable that a wind farm would be a point of interest to tourists.
HA: Tourist interest in wind farms is a travesty of fact and experience.
HC: Last sentence justified by reference to tourism and recreational attitude surveys or deleted. Doubtful if compatible with Para 16 of NPPG 14 re wild land.
HP: A number of tourist authorities are concerned about the negative effect on tourism due to wind farms. Other bodies such as the Ramblers' Association also concerned.
KGB: "Moreover, some renewable...." Subjective and taken from wind energy companies propaganda sheets. Ignores cumulative effect of developments and views of major countryside and walking organisations.
LLTNPIC: NPPG should make reference to:
Statutory requirements for a co-ordinated approach to achieving the four National Park aims when considering the scope for development.
Qualities of National Park as set out in Designation Order are not damaged or compromised.
When conflict occurs Sandford Principle applies.
Recognise role of Park Plan in setting out a renewables policy framework to give guidance on proposals and planning decisions
Need for precautionary approach before plan is adopted.
MCS: Fails to make the case for tourism strongly enough. Also fails to present the opposite view that they detract from the enjoyment of an area.
MEGA: Possibly hydro schemes may have some tourist interest - but not wind farms.
NWP: Have noted tourist and hill walker interest.
RA: RA siting strategy minimises the necessary impact on the landscape qualities of areas and therefore the large potential effect on recreation and tourism.
Suggest novelty of wind farms soon wears off.
Developments must not restrict access to particular areas.
RM: Statement naïve.
SCA: Important right emphasis is laid on the loss of recreational activities i.e. canoeing that could result from hydro schemes. Discussions with relevant bodies re design may make it possible to reconcile hydro schemes with the conservation of the natural heritage.
SLF: Supportive of statement on tourism. The phrase "through careful and sensitive siting and design of renewable energy developments, the impact can be significantly reduced" should be flagged up more positively to planners.
SNH: Last sentence misleading in two respects;
While still a novelty renewable may draw sightseers, but unlikely to continue to be true as the number of developments increases and novelty wears off, and
Quality of the recreational experience is substantially modified. Suggest should be expanded to refer to the basis of some recreational experience in wild land qualities, as outlined in NPPG 14, and the aspects of people's enjoyment covered in NPPG 11.
SRF: Welcomes the statements on tourism, but does not believe there is any evidence that renewable energy projects impact directly upon tourism and recreational activities during their operation.
3 rd sentence implies visual impacts adverse and must be minimised. Believe not required given the existing coverage of landscape and visual effects within the guidelines.
SS: Inclusion of recreational interests welcomed. Re Hydro schemes - design should take into account existing fishing, navigation and water sports and also the potential to enhance or introduce these should be considered.
NPPG should also recognise the potential adverse effects these schemes may have on the qualities of wilderness and remoteness that may be integral part of the enjoyment of climbing/hill walking.
SWLG: Abundantly clear that Scotland's tourist industry in the countryside is founded on great natural landscapes and ability to 'escape' from industrial developments. Last sentence - removed or modified so that any adverse impacts on existing tourism and recreation activity should be considered in weighing up planning applications for renewable energy schemes.
VJ: Naïve that visitors come to see wind farms.
WM: No long term interest in wind farms from tourists or hill walkers.
AHSS: Not provide an adequate framework for such considerations - suggested extra paragraphs re built heritage may be suitable here.
APRS: Developer obliged to inform and engage community. Line 7 replace "can help" with "is obliged".
BWEA.: 1 st sentence more appropriately state that siting of developments sometimes raises concerns prior to construction / development, generally due to the novel nature of the development. Not aware of siting concerns amongst residents subsequent to development.
Too vague to ask that the "amenity is not adversely affected significantly" as the concept of amenity is not one that is defined. Given that amenity issues are known to be raised during planning, appropriate for amenity issues to be given greater consideration within the NPPG and to make clear what issues are material factors within planning.
Furthermore, this clause uses terms such as "local residents" and "people living nearby" which it is not possible to define.
Suggest that the entire clause re-worded in the following way:
"Whilst the proposed siting of renewable energy developments can sometimes raise concerns among local residents this should not of itself prevent development, providing that potential disturbance, including impacts on residential amenity, can be reduced to acceptable levels. It is important that proposals for development, including access arrangements, address residential amenity and ensure that, by a careful approach to all relevant issues, residential amenity is not subjected to significant adverse effects. Development plans can helpfully set out criteria for the assessment and, if necessary, reduction of acoustic effects, but other effects on residential amenity will be less susceptible to development plan advice, requiring site specific assessment. It should be stressed that developers can help themselves by actively informing local residents about their proposals and the likely effects of development".
ELC: Advice re proximity to settlements - inadequate and suggests minimal protection will be afforded to people living near proposal sites.
HE: Text refers to non-local developments, this is likely to change in the future - worth mentioning local economic benefits.
HP: Effect on house prices would indicate people do not wish to live near wind farms.
MEGA: Noise dealt with much more thoroughly in previous NPPG. Is noise now not an issue?
NWP: Very concerned that "automatically" removed from 2 nd sentence.
Does "amenity" mean public/private? LAs lump together diverse objections under this banner. Where scheme refused on "amenity" issues - need to be closely defined.
Full assessment of properties within agreed distance of a proposal be defined during scoping and submitted as apart of application.
All impacts measured and not subjective.
Changes in view from property should not be a material consideration.
PR: LAs can also help in providing information. Suggests add "Planning authorities should make available to local communities information on the benefits of harnessing renewable energy".
RA: Guidelines to set out strict criteria for consulting local residents and to provide extensive and neutral information in the form of an audited EIS.
RDC: Little concern from residents once built - needs to be reflected in wording.
RTPI: Should be updated in the light of the implications for urban areas introduced by paragraphs 14-16.
SNH: Check list of those amenity factors which should be considered in relation to proximity to settlements:
SRF: 1 st sentence more appropriately state that siting of developments sometimes raises concerns prior to construction / development, generally due to the novel nature of the development. Not aware of siting concerns amongst residents subsequent to development.
Too vague as concept of amenity is not one that is defined. Appropriate for amenity issues to be given greater consideration and make clear what amenity issues are material factors within planning.
Terms such as "local residents" and "people living nearby" not defined.
Additional Policy Guidelines for Individual Technologies
ARIS: Separate paragraph in this section dealing with the cultural heritage/historic environment/built heritage. A large number of Scotland's best preserved archaeological sites and landscapes lie in upland areas, the very areas of search for wind farm sites. In the absence of a dedicated section the comments are given for existing contexts.
RTPI: Welcome the significant updating of guidance on various individual technologies.
SCF: Benefit by including final paragraph detailing the importance of offshore wind, particularly due to the energy advantages deriving from laminar flow and from the higher wind speeds over the sea; a brief statement of the current state of the regulatory framework (in order to signal the different regimes that might apply - understood that the DTI and the Crown Estate are discussing the details of a future regulatory framework) and an outline of the types of issue on which planning authorities may be expected to comment when offshore wind farm proposals begin to come forward.
APRS: Use of single indicator too simplistic in developing a local strategy.
BWEA: Electricity grid constraint issue should not be included here.
The implication that suitability for wind power is determined by cross-referencing the two maps is an over-simplification of the site selection process.
Map 2 does not accurately reflect the wind resources within Scotland and appears to have been modified in some way. Note that not normally constrain wind development by assuming either a 10m/s maximum constraint or a lower level of 7.5 m/s. The upper wind speed constraint might easily be removed and the lower one reduced to 7 m/s. Note, however, that the latter figure is merely an economic constraint and that turbine technology is being developed to economically harness lower wind speeds (this is already happening in the rest of Europe). Map 2 should therefore be reproduced without any modification to the raw wind speed data, but should be noted clearly as being provided purely for information and not for the basis of policy.
FR: Agree wind most likely technology in near future.
HA: Developers not influenced by mean wind speeds - map inserted for propaganda reasons.
HC: Wind section - much could go into PAN and should focus on policy.
No inclusion of offshore developments which can have various impacts.
HP: Show mean wind speed - more useful to show integral of the wind speed in the velocity band used by wind turbines. Hilltops tend to be gusty, offshore wind is far more consistent.
LP: Negative aspects of wind farm developments glossed over in section on wind.
RA: Landscape quality must provide caps on the proportion of the technical resource which is exploited, as provided in RA siting strategy. Full range of renewable energy technologies, including onshore and offshore wind should be exploited in a balanced fashion.
SRF: Grid constraint issue should not be included here.
Implication that suitability for wind power is determined by cross-referencing the two maps is an over-simplification of the site selection process.
RA: Acknowledge comment.
NWP: Advice on treatment of anemometer masts required.
PR: Amend as below ".....wind capture, turbulence, access and power line linkage any adverse effects on environmental resources and local communities."
RA: Insert landscape.
RSPB: Some respondents may be supportive of locating wind farm developments within existing forestry plantations. While there may be benefits associated with using existing infrastructure and potential landscape benefits, impact on nature conservation interests is unclear - should be subject to further, more detailed evaluation.
ARIS: Also Para 37 Include reference to historic landscapes and could refer also to the Historic Landuse Assessments being promoted by Historic Scotland.
BWEA: Acknowledgement that for wind energy the landscape and visual impacts are largely reversible. That is, the most significant aspect of impact is the turbines themselves and the removal of these would virtually eliminate the impact.
Concerned that reference to "wider setting" of designated landscapes might afford them a greater influence outwith the designated boundaries than might have been intended within their designations. Appears almost redundant given the clear wording in Para 19.
Introduces reference to natural heritage and tourism interests under the heading of landscape and these issues might more appropriately be dealt with under sections 44-48.
CC: Clarify why areas affected by mineral extraction more easily able to accommodate wind farms than others?
DMJ: See SLF comments.
HB: Supports use of central belt as place for wind farms.
HP: Such areas need full protection not a "cautious approach."
LEC: ".and their wider setting". How wide does the NSA / National Park have an influence on the surrounding landscape quality?
NP: Concerned those areas identified in 2 nd sentence will be considered as the only suitable location. Some of the most contentious applications south of the border have been located in this type of area. Adopting best practice, early scoping and consultation with planners should avoid need for statement.
PR: "wider setting" and "tourism interest" too difficult to define and should be removed.
RA: RA siting strategy recognises that Scotland has a variety of landscapes. Regional strategy ensure that the externalities of large scale developments are located close to population centres such as the Central belt yet rural communities could also benefit from development appropriate to the population. Use of national carrying capacity surveys for wind farm development would guide development to certain regional areas and prevent over development.
RICS: Agree cautious approach re National Parks and NSAs.
SLF: Hard to link mineral extraction and holes in the ground with wind power.
Accept degree of caution needed but by no means automatic exclusion in National Parks and NSAs.
SNH: LA invited to consider whether wind energy developments could be accommodated within landscapes damaged by past mining development.
"Scotland has a variety of landscapes. Some are able to accommodate wind farms more easily than others are. A cautious approach should be adopted for landscapes which are highly valued, a fact which may be reflected either through designation, or through other evidence of their outstanding value for recreation, amenity, or tourism. Landscapes which are already developed with large scale industrial structures, like harbours and ports, may be able to accommodate wind energy development relatively easily. Wind farms may also be able to be accommodated within some types of forested landscape which are already man-modified and where vehicle track infrastructure can serve both functions."
SWLG: Stronger deference expressed in siting of wind farms in wild land areas whether designated or not.
WM: Para 36-38 Wind farms can't be a minor element in the landscape.
APRS: LA to be given guidance on sources of data.
BWEA: See SRF comments.
CP: Fife LCA makes recommendations re wind farms that are unfavourable.
DGC: Reference to LCA noted though should be more expressly dealt with in earlier discussions on landscape.
DMJ: See SLF comments.
ELC: Too much reliance on SNH LCAs - assessments only provide broad landscape types and are not suitable for evaluating the ability of a landscape to accommodate development.
FES: See FET comments.
FET: See Paras 14, 16, 33 and Maps. Prefer criterion based assessments of developments as conditions within a 10km grid can vary tremendously.
LEC: 'local authorities should provide a local interpretation.' Any examples where they provide different landscape character assessments versus national guidelines? Does this give too much scope for personal preferences/interpretation by planning officers?
LPA: Opposed to locational guidance and especially to this paragraph and work by SNH on LCAs - too broad-brush to be given priority in NPPG. Draws attention to Chris Blandford's study re the above - terms of the document read to the letter would make the aims and objectives of the guidance difficult to meet.
NP: LCA not been subject to formal public scrutiny, inconsistent in approach and content - could easily be misinterpreted.
NWP: Concerned at the prominence given to Landscape Character amongst a number of other factors and constraints affecting choice of site - note that the various studies have come to different conclusions, and particularly that one recent study appeared informed by prejudicial assumptions. Landscape character should be seen as just one of a number of criteria against which proposals should be judged - strongly resist the suggestion that it should be the starting point when developments are considered. Scoping discussions with all statutory consultees and relevant NGOs will indicate major considerations.
PR: Useful that LA provides interpretation of LCA. Suggest amending penultimate sentence as below "......local interpretation to provide more specific guidance. Such guidance should not be used to limit the practicality of developing schemes in otherwise suitable areas."
RA: Should be a statutory duty on LA to provide a local interpretation of a strengthened version of SNH's LCA, and to use this as a guide in determining appropriate local sites and the extent of carrying capacity in their area alongside other considerations.
RTPI: Reference to value of LCA highlights main difficulty LA and developers will have in applying the criteria of the NPPG without any clearer national spatial strategy for renewable energy developments, particularly wind farms. LCA exists for the benefit of spatial analysis at a national level as well as a local level. However, in leaving local authorities with no overall national spatial guidance, the options remaining include: -
1) After excluding internationally and nationally designated areas, to use the LCA reactively in the appraisal of individual proposals (identifying preferred areas using LCA over the entire remaining area would be a huge task); or
2) To exclude a much wider range of international, national and locally designated areas and to examine the potential of the remaining area with the assistance of the appropriate LCA (this presumes that large areas are no-go areas for development).
Both options demonstrate the difficulty in using LCA coupled with this NPPG in the absence of national spatial policy.
SAC: Paragraphs use of LCAs does not appear to alter context set in Para 21.
SLF: Interested to see list of 29 assessments made by SNH. Should not be SNH but LA who are final arbiter re application.
SNH: 4 th sentence 'While not directed specifically at potential wind farm developments, these assessments help in enabling the different implications of each landscape character type for wind farm development to be evaluated.'
Last sentence: suggest 'discuss' would be better than 'clarify', and at the end of the sentence 'in natural heritage terms' should be added.
SRF: 2 nd sentence introduces ambiguity by stating that 29 separate assessments have "also" been completed - believe these are the national programme referred to in the first sentence.
Some of the landscape character assessments evaluate potential for wind power developments directly.
Note assessments not standardised and therefore different interpretations arise (and different terminology is adopted) in different areas. They are not sufficiently robust to form the basis for national planning policy.
Detailed landscape character assessments undertaken by developers should be the basis for proper consideration of each project proposal.
Do not believe that landscape character impact necessarily the starting point for site selection, but is one of a range of effects that need to be considered in site selection.
WDC: LCA as a tool to assist in the locational framework for new developments is welcomed.
Suggest that assessments that consider environmental capacity have an important role, and therefore studies that incorporate wider planning issues and are not solely landscape character assessments have a central role in identifying preferred locations for new developments.
AHSS: Where wind turbines situated next to historic sites - care taken with design, cite turbine next to Langwell House, Caithness as acceptable.
BWEA: Term "impact" tends to create negative connotations and would prefer the title "Visual Effects".
In describing wind turbines, the rotor size should be clearly stated as either radius or diameter.
Remove the reference to "areas protected for their landscape quality" implies that wind farms should be concealed from such areas.
Whether a wind energy feature is dominant in the landscape depends upon a number of matters including the presence or absence of other features in the landscape, the design of the development, the nature of the views, the context of the view and changes that take place with the seasons. Noted that the perception of impact is entirely subjective and it should not be assumed that a "dominant feature" is necessarily a negative feature. In nearly all public attitude surveys of existing wind farms in the UK, the majority of locals express a positive supportive attitude and there are regular statements made that turbines are "elegant", "attractive", "symbolic" etc.
The table of "perceptions" of impact is likely to be prejudicial, during planning applications, to the application of a rigorous, project specific, visual impact assessment which will consider all the relevant factors.
The table on likely "perception" would appear to be inappropriate in the context of an NPPG and would ask that it be removed. It might usefully be replaced by some advice such as:
"Significant visual effects of wind turbines are only experienced within 5km; beyond 15km wind turbines can generally only be seen in very clear visibility and even when visible are likely to be a minor element in the landscape".
CG: Para 38-41 Table must take into account turbines at rest. Moving blades intrusive at up to 30 km.
Shadow flicker does not appear to take into account people with epilepsy or similar condition.
CP: Sizes out of date - 80m more likely as a maximum.
DGC: Para 38-41 Attention given to visual impact welcomed.
HC: Table should take into account clear visibility in rural Scotland - Novar clearly visible at 30 km.
Depending on landform may not be a minor element even at those distances.
More helpful if policy connotation was given to the description of different dominance's.
HE: Suggests addition of "Some single turbines or small clusters will be sited near commercial premises." before domestic turbines.."
HLP: No source for table - requires considerable justification. Other factors, not just distance involved. Dangerous and should be removed.
JD: Table figures not realistic as turbines getting bigger all the time.
KGB: Supports development in less exposed sites near centres of consumption.
Table plays down visual impact of turbines at intermediate distance. Contradicts the accepted Thomas/Sinclair matrix which has been used at a number of inquiries.
PE: Produce smaller wind turbines - often asked to provide similar levels of documentation even though of several orders less in magnitude to larger turbines. Looking for clarification of lesser effects of smaller turbines.
Replace "Domestic turbines will be smaller" with "Domestic turbines will be very much smaller and will have little visual effect outside the immediate site".
PH: The sole criteria should be whether they cause a visual intrusion - they should be dealt with as any other development.
Amended text - "siting should not be allowed in situations where visibility would be detrimental to the visual enjoyment of the unspoilt areas".
PR: Useful guide. Suggests amending "rotors 15 - 20 metres" with "blades 15-30 metres each in length" in 1 st sentence. Suggests amended table as below.
2-5 km Relatively dominant within a specific field of view > 15km Only seen in very clear visibility (if at all) - a minor element in the landscape.
RA: Welcome that developers should seek to ensure through good design that the visual impact is appropriate to the location. Requires proper assessment of features and quality of the existing landscape and its presentation in a Photomontage and Zone of Visual Impact Map in an EIS, and the implementation of any possible mitigating possibilities.
RDC: Rotor size wrong - 1.5MW turbines can have diameters of 70 metres.
Modify wording re "high open land" to add "...but may also be sited within suitable forested areas."
RIAS: Para 38 - 41 Provides ample guidance on design.
RICS: End of third sentence replace with "....it may b e unrealistic to conceal them". Have experience of doing so.
RJHW: Para 38-41 Draw attention explicitly to potential contribution of Landscape Architects in achieving best fit.
RM: Little dated. Currently proposed schemes blade-lengths of 28 metres.
Given the fact that most objections are based on visual impact and several have been rejected on those grounds even after Inquiry this section is probably inadequate. Better guidance possibly solve such problems at an earlier, less costly stage.
In particular the NPPG might usefully refer to the Sinclair-Thomas Matrix for estimating visual impact. Mr Sinclair willing to engage in dialogue with SE.
Suggests Paras 40 and 41 might also be usefully reviewed with his input. In particular the '10 rotor diameters' rule of thumb and the relevance of swept rotor area need to be examined in the light of recent experience.
RTPI: Source of table requested.
SNH: Takes issue that on high land - only there due to incentives.
3rd sentence Turbines may be clearly visible but have low visual impact if they have been well located, sited and designed so that they 'fit' landscape character.
Not agree is reasonable to seek to conceal wind turbines in protected areas. Generally not possible or desirable to conceal wind turbines, domestic or commercial, within or outwith protected areas.
This section does not very successfully convey message that the planning system should be seeking to understand landscape character, and find a strategic approach which places the right kinds of development in the right places.
5 th sentence - need to convey better the importance of relationship between the development and the character of the landscape. Suggest: 'The visual effect will be dependent on the character of the development in relation to the character of the landscape, the nature of the visibility, the distance over which the wind farm tends to be viewed, and different weather conditions'.
Table on visibility is reasonably useful, although visibility is also strongly affected by other factors. Suggest the last sentence be qualified by 'though visibility is strongly affected by other factors than proximity, including the quality and direction of the light, and colour and layout factors as described in the following paragraphs.'
SRF: Rotor size clearly stated as radius or diameter.
Consider reference to "areas protected for their landscape quality" removed, implies wind farms should be concealed from such areas.
Table on likely perception inappropriate an NPPG. Whether a dominant feature, in turn, represents a negative effect or more importantly an unacceptable negative effect, is a highly subjective issue.
BWEA: See SRF comments.
HC: Would be greatly improved by revision by a landscape architect knowledgeable about wind farms. What is a concentrated wind farm? How are wind farms complex? And how are they confusing with regard to landscape character. Is there policy merit in stating that wind farms can be "simple"?
MEGA: Rows of turbines can be intrusive (Denmark as example) - suggest examples as good and bad practice.
PR: 2 nd sentence difficult to substantiate and not in context with rest of paragraph - should be deleted.
RTPI: Source for the indication of public preference for wind farm containment within the landscape should be quoted. Also deal specifically with the impact in flat lowland landscapes as a result of the identification of the central belt in paragraph 16.
SNH: "landscape character" more comprehensive.
SRF: Not aware of definitive assessment of public preference for wind farm layout.
These comments are specific to wind farms and not necessarily to smaller wind developments involving, for example, 1 - 5 turbines.
BWEA: Reference should be made to semi-matt surfaces.. The sentence might be amended to state:
"A semi-matt surface may be preferred to reduce the reflection of light, appropriate to the project design".
Reference to ancillary elements appears to be too vague and requires additional clarification. It is unlikely, for example, that anemometery towers will give rise to visual impact due to their design. The design and routing of power lines from a project are usually subject to a separate application (see Para 47, bullet point 4) and are usually outwith the control of the project developer (as they are often designed, permitted and installed by the host electricity company). The sentence might therefore be modified to:
"Ancillary elements, such as access tracks, fencing and building also need to be considered".
ELC: Scope to effect impact through design is minimal - to reflect that LA should be able to control whether an area is suitable.
MCS: Comments re ancillary elements woefully inadequate. Considers bulldozed tracks lie outside planning system and should be brought under such control. Should provide LA with powers to recommend refusal or less damaging alternatives.
NWP: Replace "matt" with "semi-matt" as paint type successfully used in Scotland.
PR: Could refer to relative merits of 2-bladed and 3-bladed turbines - 3-bladed generally regarded as more visually acceptable.
Suggests omitting "raise issues which"
RA: EIS to include mitigating action they taken to ensure impact of development are minimised. Include demonstrating that through good design the visual impact is appropriate to the location, the design of each development is appropriate to its site, the style and colour of the turbine is appropriate, the effects of ancillary elements such as access tracks, power lines, fencing, buildings and anemometers are minimised.
SNH: Draws insufficient attention to the visual impacts of access tracks, power lines and associated buildings. Like to see sixth sentence in this paragraph expanded into a paragraph of its own, can be expanded upon within the proposed revised PAN.
Suggests "Access tracks can have severe landscape and visual impact due to the linear and usually contrasting forms of the track, cuttings, embankments and drainage channels. Access tracks associated with wind farm developments can have almost as much impact as the turbines themselves. It is not only on hilltops where tracks are of concern -they can also cause impacts across other types of landform such as moorland. The total length of access track can be minimised by good siting and layout of a wind farm. Their visual impact can be minimised by careful route selection, layout and appropriate surfacing materials. Managing problems of erosion and providing for reinstatement of vegetation along the track is essential".
SRF: Reference should be made to semi-matt surfaces or colours.
Reference to ancillary elements appears too vague and requires additional clarification. Unlikely anemometry towers will give rise to visual impact due to their design.
BWEA: Whilst supporting the principal of wind turbines being located 10 rotor diameters from settlements, this may in some cases be inappropriate for single dwellings and should be a policy constraint only where the proposed project actually has an effect upon the visual amenity of the dwelling or settlement.
Guidance on rotor diameters is based upon visual effects and should not include a reference to "noise disturbance" which should be dealt with under Para 42.
Guidance on proximity to roads might usefully indicate that there are existing wind farm developments either highly visible from roads or with roads passing through the development (and these developments exist within Scotland - for example Hagshaw Hill near the M74 and Dun Law on the A68).
CP: Due to interest in smaller scale developments - not a good paragraph and may make approval more difficult.
Does not seem to make allowances for a distributed development model, which has a number of technical advantages (some of these have for instance been put forward by Amory Lovins of the Rocky Mountain Institute) and is particularly suited to real community development as has been well demonstrated in Denmark. (And this model of development can achieve large deployment of wind power in total.) The scale (and perhaps type?) of developments should also be a relevant consideration in determining the acceptability or otherwise of siting proposals close together (which is more likely to occur with distributed development).
Guide figure based on rotor diameters is probably simplistic and a figure of 10 diameters probably excessive. The current PAN 45 in paragraph A.37 suggests a distance of 350-400m (maybe less) to avoid noise problems and in paragraph A.17 says a distance based on noise will be greater than that necessary to meet (physical) safety requirements. Taking the most recent series of Vestas machines, the V52 (a replacement of the V47), V66 and V80 (rotor diameters 52m, 66m and 80m) as an example (where other factors are held reasonably constant) the minimum distance required to achieve less than 41 dB(A) is 300m, 320m and 340m respectively.
The use of a multiple of rotor diameters as a guide is of even less use in avoiding "shadow flicker". Definition of "shadow flicker changed from PAN 45, Para A22 deals more clearly with these issues.
ELC: Fails to deal with cumulative impact - public unlikely to be reassured by recommendation that wind farms can be sited as close as 130 metres from a dwelling.
HA: 10x scarcely distant to boundary of the site - at variance with Para 38.
HC: Confusingly mixes cumulative impact and impact on nearby residences - separated and considered in turn.
10x rotor diameter appears too close for noise and likely to be inadequate for visual amenity. Should be clarified with table in Para 38.
HP: 10 rotor blade lengths not sufficient - shed ice when starting up in cold conditions and possibility of collapse - worried some one could be killed.
JD: Merges cumulative impact and separation distances from residences. Issue of cumulative impact needs to be considered in more depth and is likely to become more of an issue for areas with significant developer interest.
KGB: Trying to make cumulative wind farms acceptable. Jargon around LCA will make it difficult for lay people to argue on grounds of cumulative impact.
LEC: The cumulative impact issue for wind farms will be a significant contentious aspect over the next 5-10 years predicted expansion is to happen. Should have greater prominence in NPPG6 and therefore the document should be more prescriptive Should there be provision for the creation of wind energy landscapes where this form of renewables becomes the defining character?
2 nd sentence: 'siting proposals close together.' Define categories of 'close' as per table in section 38.
3 rd sentence: why have a prescriptive 'separation zone' when will be the case that community scale developments should be functionally close to the user. Where is the difference from the household or industrial user's perspective in power consumption from community or grid linked projects?
Should these distinctions be material planning considerations?
Last sentence: where are the hard examples of 'driver distraction' from SE RNMMD?
MEGA: Cumulative impact "must" not "may" be a relevant consideration especially if grid constraints put wind farms in the central belt. 10 rotor diameters is quite inadequate re noise, perception and the routing of overhead power cables.
MoC: Recognises cumulative effects.
PR: As wind farms become more common, questions distraction of drivers and effects of shadow flicker - suggests final sentence removed.
RA: Study of carrying capacity of area would address issue of cumulative impact.
RDC: Prefer less specific re 10 rotor distances Add "The separation distance will be influenced by the specific design of the proposal, and nature of the localised landscape, but as a general guide a distance equating to 8 - 10 rotor diameters..."
RTPI: No criteria suggested for the reduction of the cumulative impact of neighbouring developments. Argyll and Bute Council recently considered applications for two wind farms in relatively close proximity along with concerns expressed about the cumulative landscape impact on the potential loss of local countryside, which would be caused if both wind farms were developed. The lessons from this case could be quoted. Should be recognised that flicker can affect drivers on adjacent roads as well as residents in adjacent dwellings.
SNH: Suggest that a separate paragraph on cumulative impacts is required under the 'landscape' heading, saying:
"The nature and character of an area, and its landscape character, will in part determine the acceptability of siting more than one development in one area. Consideration should be given to the acceptability of the combined impacts from a proposed development in combination with existing ones and those already granted planning consent."
Second issue is of separation from settlements and dwellings, and here visual impacts, noise, amenity, health, safety, shadow flicker, driver distraction, and telecommunications impacts should be referred to.
SRF: Requirement for a separation distance based on rotor diameters should not include noise issues, as that should be dealt with under Para 42.
Clearer if clause divided into two to clearly distinguish (i) between cumulative impacts and hence spacing between projects and (ii) distances from projects to settlements and dwellings.
Guidance on proximity to roads might usefully indicate that there are existing wind farm developments either highly visible from roads or with roads passing through the development (and these developments exist within Scotland).
SWLG: Also Para 42 and 47 - Not just footpaths but well established walking routes be considered when considering locations which can be adversely affected.
WM: Separation distance inadequate - noise nuisance bad at 2km. Medical evidence exists that are detrimental to health. No turbines within 2km of a dwelling.
McA: Low frequency noise is persistent and debilitating. Considers an outrageous lie used to justify the unjustifiable.
BWEA: See SRF comments.
CG: 10% of PPG22 discusses noise.
No mention of very low frequency noise - can be felt at up to 8km. Developers to be required to include in their assessment.
DCC: Noise and also visual impact cannot be underestimated. These issues raise much controversy.
DGC: Welcomed. Guidance on monitoring and use of conditions would also be welcome.
HP: Turbines may be quieter - however warping of blades to protect turbines from damage in wind gusts causes there to be more noise.
MEGA: Where noise is shown to annoy, it should not be allowed to occur.
PE: Add that on calm nights - no noise. Not easy to provide full noise data for domestic turbines. Noisy turbines should be differentiated. Recommends national register of wind turbine noise reports at NEL.
RA: EIS should state site specific information about the potential noise impact, site modelling and measurements, propagation, monitoring, background noise levels, mitigation and possible variants. LAs ensure that noise levels will not be intrusive in relation to background noise at the nearest dwellings. The potential impact of noise on outdoor recreations such as hillwalking and amenity value must be addressed within an EIS and mitigating measures outlined.
RM: More true to say, "Modern turbines are less noise than their predecessors of similar size."
Noise standards and the noise models used are inadequate.
Authors of the ETSU document envisaged its findings to be reviewed no later than 1998. It is thus out of date, by its own recommendation, by more than two years
Noise nuisance problems have been found at wind power developments which were given a clean bill of health by BS4142 and the ETSU recommendations. Best to place a larger quarantine area around wind power developments.
SRF: BS4142 is not appropriate for assessing noise.
Suggests that project should meet criteria laid down in the DTI report mentioned.
VJ: "no nuisance should arise" Considers that it is peace and quiet countryside that attracts visitors and those turbines have an "irritating" noise.
BWEA: In relation to airfields and flight paths, reference should be made to CAA guidelines CAA99/002.
Where conflict exists between Private Air Traffic Controllers and the CAA on matters of planning objections to wind turbines, the matter should be referred to the Scottish Executive Planning Department for arbitration.
CG: Effects on radar significant and cannot be mitigated by electronic means - ban in visible areas around installations.
TV reception can be disrupted - developers required to restore reception when effects TV.
Wind farms to be excluded where affects mobile telecommunications.
DGC: Guidance on role and weight given to views of consultees should be given. E.g. the use of exclusion zones by some consultees is questioned by developers.
HP: Developers should be liable to ensure no loss of electronic amenity - even if involves a new transmitter.
PR: Suggests "driver distraction" removed - reasons cited in Para 41.
RM: Dealt with simplistically by developers and residents experience problems outwith the area predicted. A distance of up to 1km of influence for 40m rotor diameter has been found. Calls for the precautionary principle to be applied. Minimum separation distance of 1km from neighbouring properties would not overly restrict the number of available wind resource sites.
Work at the Macauley Land Use Research Institute allows realistic simulations of visual and sound effects from wind turbines. Also, a simulation tool "Wind Park Wanderer" allows walk-throughs to show the effect of shadow flicker and noise contours. Not unreasonable with this technology available to require its use in informing planning bodies of the likely consequences of a development.
SRF: Airfields and flight paths, reference should be made to CAA guidelines CAA99/002.
SS: Consideration should also be given to non-commercial flights such as gliders, balloons etc sportscotland should be consulted where recreational interests may be affected.
BWEA: See SRF comments.
DGC: To Para 46 - welcomed.
FC: Impact on flight path of designated ornithological site to be determined
HP: Developers required to consult experts who have no financial interest in the development such as the British Ornithological Society.
LEC: 1 st sentence to include: 'Based on examples of wind turbines in a wide variety of habitats studied in the UK and Europe so far, the impact of appropriately designed wind farms on the local bird life is minimal'. Why make the distinction of local versus non local birds: studies in Europe indicate there to be negligible impacts on nocturnal migrants as well. The importance of wind farms in the uplands based on experience to date, the future wind farms are likely to occupy other sorts of bird habitat. Second sentence: tending towards a blanket prescription against any sort of development in SPA areas...which will not be the case... there should be reference to decisions based on the best available knowledge of species and potential risks and also no hiding behind the 'precautionary principal' which is not a helpful, proactive way in which to make decisions.
3 rd sentence: '...should not adversely affect..' replace with "should not have a significant adverse impact'.
MEGA: SPA "will" present a constraint not "could" - refer to wind farm proposal in Kintyre.
PR: Use "effect" instead of "impact" in this paragraph and throughout the document.
Penultimate sentence should also refer to size and speed of blades in relation to effects on bird populations.
RA: Visual impact standards should be similar to applications for most types of industrial development.
RM: Also Para 45 - Sound guidance however, depends on proper surveys being carried out.
RSPB: Welcomes the point that protected species range beyond protected sites. However gives impression that developers need only concern themselves about species which have ventured beyond the boundaries of nearby sites. Clearly not the case, there remain many areas of Scotland where Birds Directive Annex 1 species would be adversely affected by a wind farm developments but there are no designated sites near by. Recommend amending 4 th sentence to read 'Protected species can be found outwith designated sites but must still be protected'.
Indicates that collision risk is the most common concern, however, it does not make clear that if developers feel there is a risk then that risk should be clearly identified and evaluated, to enable informed discussion (as was debated at the Islay wind farm inquiry).
Further significant issue is the loss of open habitat for birds such as the golden eagle. In areas where there has been a loss of open countryside in recent times (for example through commercial afforestation) the cumulative impact of wind farms plus forestry can lead to a significant loss of suitable open habitat. The 'Beinn an Tuirc' wind farm application in Argyll and Bute was considered by the Council together with another wind farm application. This was due to concerns about the cumulative landscape impact and the potential loss of open countryside caused by two wind farms in the same area. Commend this approach and suggest that planning authorities should be advised to consider the cumulative impact of wind farm developments, not just in relation to other development proposals but also with regard to historic changes in the land use.
Historically wind farms have been located on upland habitats, hence the body of information we now possess regarding potential impacts. Given the emphasis of the NPPG and the potential flexibility of the Utilities Bill it seems likely that wind farms will no longer be restricted to these sites. Consequently this paragraph should make it clear that there can be potential problems relating to birds (collision, disturbance, habitat loss etc) in the lowlands, on the coast and at sea (for example on migration routes).
Unclear as to the intent or meaning of the final sentence in this paragraph, is it simply alerting planning authorities to the fact that while birds may be present there may also be other habitats and species, if so perhaps an example would be appropriate (e.g. Peatlands)?
Section touches briefly on so many issues that the attempt to summarise them falls short of being useful, perhaps it would be appropriate for the NPPG to flag up that the issues touched upon in this section will be elaborated upon in far more detail in the forthcoming PAN.
RTPI: 2 nd line, reference to upland areas derives from the predominant concern hitherto with regard to upland sites for wind farms and their effect on upland habitats. Draft emphasises the scope for lowland locations and it is equally possible that these could conflict with species and sites covered by the EC Birds Directive.
4 th sentence rightly refers to circumstances where protected species may range beyond protected sites but this is not the only situation in which protected species may be found. Suggest sentence should read "Protected species can be found outwith designated sites but must still be protected". A great deal has been learnt from recent cases with regard to the protection of birds and habitats and further guidance could be included here (e.g. on the Section 75 Agreement for the Kintyre Wind Farm) or in the updated PAN. Would also be appropriate to add an example of other habitats in the last sentence of the paragraph (e.g. peat lands).
SNH: Also Para 45.
SRF: Test for impacting on an SPA or SAC should be a "significant adverse impact" on the integrity of the characteristics for which protection was originally sought.
WWF: Sees potentially large growth of offshore wind - further guidance required re siting and operational with respect to wildlife conservation and environmental concerns. Disappointing wind survey did not include offshore areas.
BWEA: See SRF comments.
FC: Many species and habitats exist outside designated areas and of importance - include in line with NPPG 14.
PR: Suggest amend "....taking ameliorative or mitigating action or, if acceptable solutions do not exist, seeking alternative sites nearby." Mitigating factors may include provision of new habitats etc.
RDC: Amend "early discussions with SNH, RSPB and other ecological organisations..."
RSPB: Simple message that conflict can be prevented and solutions found by identifying constraints, sieving sites against these, and talking to those who represent various sectoral interests should be repeated in this section or detailed in the forthcoming PAN. A number of environmental NGOs can provide information to developers, not simply SNH, text should reflect this.
SNH: Equal standing to (actual and potential) SPAs and SACs. As regards European framework, it also needs to give a clearer guidance on habitats and species listed on EC Directives where these occur outwith designated areas. Re-writes paragraphs.
SRF: Simplified to "Developers should enter into early discussions".
Not appropriate for the planning guidelines to advise that it is the role of ecological advisers and SNH to discuss "seeking alternative sites nearby".
BWEA: "Methodology for Assessing the Effects of Wind Farms..." prepared by the BWEA and suggest that the start of this sentence be changed to:
"Additionally, the British Wind Energy Association and SNH are jointly preparing...".
CG: Asking BWEA seems perverse better to have asked RSPB.
RTPI: More appropriate to refer to "technical advice" in PAN 45.
BWEA: Proximity of wind turbines to public footpaths should only be of concern in respect of (a) ensuring that access rights are maintained over the lifetime of the project and (b) that safety is paramount during the construction phase and whilst any maintenance is taking place.
The reference to access tracks, substations and overhead power lines might better be moved to the "visual impact" section.
Note in second bullet point a reference to "reinstatement for vegetation along the track is essential". Whilst in some cases it is possible to revegetate tracks, this may compromise the safety of users of the track.
"Revegetation of access tracks should only be considered a planning matter where there are significant ecological or visual concerns which may be mitigated by revegetation. In this instance the developer should agree with the planning authority, in consultation with SNH, the degree of re-instatement of vegetation required along the track but ensuring that the health and safety of users of the track is not compromised".
It should also be noted that the reference to "the nearest point of access to the transmission / distribution..." might be simplified to "the point of access..." as it is not always the nearest point that forms either a technical or economic solution. We support the view that underground electrical connections should not be considered the "first option".
Note that for small, stand-alone systems (not grid connected) the impact of the turbine may in fact be the preferred option compared to the alternatives - grid connection by overhead line or diesel generator.
CC: Important to include grid connections in any submission.
DGC: NPPG should provide LA with the scope to ask for information on the proposed route of any grid connection and this should be assessed as a part of the whole scheme.
DMJ: See SLF comments.
FC: Advice highlight potential conflict with archaeological resources in upland, unimproved land.
HC: Undergrounding of cables is highly desirable between turbines and sub-station. Not clear from sub-paragraph.
HP: Other consideration should include public safety - developer to consult with HSE and cost - preferred option should be for underground lines with the developer required to show why this is unnecessary.
LEC: 2 nd BP Suggests over prescriptive when qualify...'reinstatement of vegetation'. Blanket reinstatement not always necessary on ecological or landscape grounds for installations in industrial/urban settings or where the vegetation is semi-natural or of ubiquitous distribution.
MEGA: Objects to the dismissing of need for underground lines in sensitive areas on cost. Reference will encourage use of overhead cables - little confidence in SE requiring underground lines - increasingly stormy weather may force generators to consider this in upland areas.
PE: Domestic turbine preferable than overhead electricity lines or diesel generator. Has sited turbines in National Park in England and was considered less obtrusive.
PR: 1 st BP - not instructive as users of footpaths cannot be assumed to hold a position on wind farms.
2 nd BP - Vegetation on track surfaces can compromise safety - need to balance safety with desirability of re-vegetation.
3 rd BP Replace "visual impact" with "visibility".
RDC: 1 st BP To include bridleways replace with "....turbines to public rights of way."
4 th BP Concerned public not aware of significant cost of burying cables underground. Suggests "... suggest that this should not be considered unless there are substantial environmental disbenefits in placing cables on overhead transmission lines."
RA: Include within carrying capacity studies an assessment of the importance of the area for recreational enjoyment of the outdoors. Turbines should avoid interfering with popular access routes and footpaths. Access must not be prevented through renewable energy development.
The listed features need inclusion within the requirements of the EIS, and should be included within the criteria of a study of carrying capacity. Locating developments close to population centres would minimise the effect on areas valued for their wild land quality. The effects of connections with the transmission / distribution grid (overhead lines) should be minimised as should the effects of access tracks and substation - reinforce that this is an industrial development.
RIAS: May be too restrictive - guidance should provide scope for imaginative and innovative design.
RTPI: Access tracks - control available outside NSA when not required for agricultural or authority use.
SLF: 1 st BP If safety problem should be mentioned, if visual impact, consideration should be made to the impact of tourism.
4 th BP The need for grid connections should be an integral part of the application. Have become used to pylons - why should we not become accustomed to turbines.
SNH: 1 st BP should capture instead the impact of the development on recreation and amenity. Suggest:
"The impact of the development on recreational access and public amenity, including footpaths and cycle ways and open access to hill land and including any impact on wild land quality which may form part of the recreational experience "
2 nd BP suggest that 'access tracks' should merit a separate paragraph under the heading 'visual impacts'.
4 th BP expressed too weakly. Partial or total undergrounding always considered as option. Reference to costs removed, with the paragraph emphasising that in sensitive locations undergrounding of power lines is a viable and environmentally appropriate action.
Also indicate that although a line requires separate consents, its impacts should be considered along with the rest of the scheme.
SRF: Proximity of turbines to public footpaths should only concern in respect of (i) ensuring that access rights are maintained over the lifetime of the project and (ii) that safety is paramount during the construction phase and whilst any maintenance is taking place. Reference to access tracks, substations and overhead power lines better moved to "visual impact" section.
Reference to "the nearest point of access to the transmission / distribution..." might be simplified to "the point of access..."
SSE: Essential consents granted for renewables conditional on approval and permission obtained for connection to distribution or transmission system.
SWLG: Most concerned over scars from bulldozed tracks - stronger message be given to require landscaping of access tracks.
Cost of underground connection should be secondary to environmental aspects.
HA: SE not given any evidence for assumption that output from wind farms will create any significant difference.
KGB: Travesty, seeks to emasculate all arguments against wind farms - easily written by wind farm developer. Locally derived criteria as in DGC structure plan dismissed and long discussions on a locally relevant document ignored.
MF: Travesty of planning - seeks to emasculate previous grounds of objection and ignores the cumulative effects of multiple sites.
RA: RA siting strategy provides positively for development by indicating where development should be permitted, and where it is inappropriate
SAJ: See KGB contribution
SNH: Suggests adding 'where in accordance with the development plan'
VJ: Appears that objections and arguments over many years will be dismissed and that the south of Scotland will be required to bear the brunt of renewable energy developments.
ARIS: Include minimising impact on the 'built heritage'.
GRF: There should be a complete ban on new hydro schemes in the North West Highlands as the NPPG does not provide sufficient protection and alleged contradicts comments in NPPG 14 concerning this area of Scotland.
HB: Supports environmentally sensitive hydro developments.
HC: See general comments re wind.
Small scale run of river 1 MW not 10 MW.
Small-scale storage systems should be mentioned with considerations of their particular impacts.
Last sentence should encourage early dialogue with LAs.
HLP: Advances in technology allow small storage schemes to be considered Should state "small scale run of river or storage schemes".
RA: Presumption against new large scale hydro developments and against smaller hydro developments within designated areas. A study of carrying capacity should study the particular issues of hydro schemes in other areas and identify whether any development or its scale and effect are appropriate to the site. Effects of any scheme granted planning permission should be strongly mitigated.
RIAS: 4 th sentence - Replace "careful" with "sensitive and imaginative design"
RTPI: Subheading "Natural Environment" appropriates. Second to last sentence - outline more clearly issues relating to hydro schemes.
SNH: Not offer guidance on the determination of hydro cases. Fit with landscape character, and compatibility with wild land values, is not simply a matter of good design. If schemes come forward in inappropriate places, it will be very difficult to make them fit. Welcome final sentence.
For impoundment schemes, consideration of landscape impacts too brief to be useful.
SRF: Not appropriate to state "such locations are potentially sensitive". Each site to be evaluated to determine degree of sensitivity.
Recognise are common issues between renewable technologies, prefer to see these set out as such (i.e. generic issues), rather than by reference to wind energy projects.
SWLG: Very concerned hydro schemes will offer small contribution but this outweighed by adverse impact on landscape. Concerned wording is such that careful design will make any scheme possible anywhere.
DMJ: See SLF comments.
HC: The need to agree compensation flow should be added.
Helpful to include comment on link between conditions/agreements and compensation flow.
RSPB: Will Water Framework Directive have implications for hydro industry?, in which case is this something which the NPPG should discuss.
RTPI: Subheading "Prevention of Pollution appropriate. Reference to Water Framework Directive appropriate?
SLF: Define "small scale project".
CNES: Welcomes recognition of impact on fisheries.
DMJ: Fish passes overstated in particular where is run of river with high head/low volume. The three types of hydro schemes have different implications for fisheries.
Fish ladders offer opportunities not just for fish but to keep water flowing over waterfalls etc.
HC: What is policy weight to be attached to fisheries?
"care is required" is inadequate.
HLP: Difficult for Fisheries Commission to give information on fish passes - should be checked.
RICS: Welcomes contact with DSFB.
SLF: Fish passes overstated in particular where is run of river with high head/low volume. The three types of hydro schemes have different implications for fisheries.
Potential for small scale or micro hydro in conservation areas.
Fish ladders offer opportunities not just for fish but to keep water flowing over waterfalls etc.
SRF: 1 st sentence - unclear of intention No detail has been given on guidance relating to "areas valued for their nature conservation interest" in relation to hydro schemes.
Reference to economic benefits of tourism ambiguous, as infers that hydro schemes are automatically prejudicial to tourism.
ARIS: Include reference to underwater archaeology which can occur in fluvial, lacustrine and riparian environments. Deposits on such sites may be particularly well preserved and are particularly vulnerable to disturbance or change e.g. in water levels.
FC: Greater importance given to far reaching implications of these schemes. Reference to potential effects on archaeological sites should be included.
GHP: Small scale hydro developments are more environmentally appropriate than wind farms.
HC: Last sentence to end ".....subject to on-going monitoring."
RSPB: Final sentence in this paragraph suggests that schemes can always reconcile their impacts upon the natural environment, not the case. Recommend the inclusion of the word 'sometimes' before 'possible to reconcile.....', to more clearly reflect what is feasible.
RTPI: Suggest rewording to last sentence "careful consideration should be given to designs which can reconcile.."
SNH: Over-confident about ease of reconciling hydro schemes with conservation of the natural heritage through careful design. Continue to be places where developments of this kind are simply inappropriate, regardless of their design.
HC: Pays too little attention to issues raised by storage hydro schemes - omits such impacts as draw down margins, breeding and feeding birds and water catchment management. SE should learn from Inquiries into such proposals as Shieldaig Forest scheme.
HLP: Re-wording to reflect that not all storage schemes need dam or reservoir - terms dam and reservoir give wrong impression of scale.
RSPB: After 'impacts on habitats' suggest including 'and water levels', as gives clearer indication of one of the key concerns raised by hydro schemes.
RTPI: Add "and water levels" after "habitats" in the last line.
SNH: New subheading 'Other considerations' as covers impacts other than aquatic habitats and species. Matters covered should include the effects associated with the intake and penstock, and drawdown of an impoundment resulting from the way a storage scheme is managed.
SRF: No guidance on the importance of each issue or how it might be evaluated. Mention should be made that the majority of these impacts take place during the construction phase and that this is a relatively short period and that the impacts are largely reversible with good management practice.
SNH: Suggest adding where in accordance with the development plan.
SS: Should be consulted where recreational interests may be affected. Also where appropriate local as well as national bodies for angling, sailing, canoeing should be consulted.
SWLG: Also Para 53 Issues raised of crucial importance - need to be addressed comprehensively not just in a "satisfactory manner."
AC: Fails to address biomass adequately, considers this a serious failing - notes £29 million from MAFF promoting Energy Crops south of border, nothing from SE.
CC: Para 55-60 Useful to add information of likely land areas required for biomass crops to produce specified energy output. Preference for material to be sourced from native species if possible.
DMJ: See SLF comments.
ELC: Guidance to acknowledge that odour may be a public concern.
FC: Biomass Para 55 - 60 Reference and guidance usefully given to the Indicative Forestry Strategies.
Heat recovery from biomass and incineration not addressed nor CHP. Municipal waste incineration and landfill gas and sewage gas are no longer included in the European's proposed definition of renewable energy resources in the draft Directive on Renewables. Would welcome guidance on these issues either within NPPG6, in wider sustainable energy context, or in separate guidance.
FCom: Make point that supply and demand are more easily matched using biomass (including forest residues and wood fuel) since biomass can be stored.
FES: Burning of waste not renewable by Government definition.
FET: Concerned that recycling will be neglected if waste incineration receives full support as a renewable energy source.
FR: Welcomes the inclusion of biomass technologies within the renewables development portfolio and wish to highlight the additional benefits over-and-above renewable electricity generation that arise from its operation:
- Employment : (3 - 5 new jobs per MW installed), maintaining rural employment and skills in the fuel supply chains and plant manufacturing and construction employment
- Environmental: CO 2 neutral conversion process. Ecological : supporting biodiversity
Predictability : biomass energy generation is closest to fossil fuel power stations in its dispatchable operation.
GCV: Although gives some guidance on waste combustion and waste to energy - wants guidance on what is and is not acceptable. Hoping PAN to provide this information.
HB: Supports provision of waste combustion sites in central belt.
HC: Disposals of waste arisings and by products to be added.
HE: Paragraph should be expanded to mention the benefits of biomass. Numerous benefits listed in submission.
ICF: Stress potential benefits of biomass for sustainable rural development over other types of development.
Use of forest wastes as energy source undervalued.
Omission that no targets for the use of energy crops.
Need for an indicative mapping exercise to highlight areas where residues are likely to be abandoned.
Need to link biomass with production of heat energy.
JD: Waste combustion separated from biomass - energy from waste put in context of national Waste Strategy. Could be material considerations and might suggest burning waste not the most sustainable method of waste management.
NLC: Energy crops will not be exploited until receive the same level of grant as in England (alleges is a quarter of the English grant in Scotland).
RIAS: Advice should refer to the standard applicable to most types of small-scale industrial development and rightly picks out chimney design and location.
RICS: Biomass has a lot going for it and should be studied further.
RTPI: Adjustment of the heading clarifies an ambiguity in the existing NPPG. Understood that this section intended to deal with general waste combustion and not just forestry waste combustion. Emphasises the point raised in our general comments about the need to recognise the difference between "recoverables" and "renewables" as sources of energy. NWS also important in this connection and this context should be stated more clearly at the beginning of the section. Potential for using biomass, also be expanded, especially in relation to CHP.
SEPA: Do not consider properties of combustion technologies are so similar as to allow policy to be the same. Waste to energy plants should, with reference to the NSW, reflect BPEO for the waste stream.
View of SEPA that all renewables that relate to waste should have policy representation under one heading rather than split between waste combustion and waste to energy. Would permit appropriate cross referencing between developments and the NWS and NPPG 10.
"(including use of rail)" inserted between "generator" and "and".
SLC: Does not discuss availability of land for biomass production, the use of derelict or underused agricultural land or the impact of a biomass monoculture. Planning system should seek to influence of such developments as was the case with the preparation of Indicative Forestry Strategies.
SLF: Encourage recycling and the separation of combustible and non-combustible materials.
SNH: Reference in Para 55 to visual impacts extended to 'landscape and visual impacts', as should the heading for Para 56.
SRF: Concerned combustion of municipal waste and other refuses should not, in planning terms, be considered the same as for biomass projects.
Useful to make some introductory statements about biomass energy systems, to highlight the range of positive benefits that such technology brings, including rural employment in agriculture and forestry, along with environmental benefits such as carbon sequestration and the utilisation of residue streams.
WWF: Concerned Biomass and incineration aggregated together. Waste incineration causes environmental concerns. Suggests split section. Parameters for suitable sites to be made clear - crops should be seen as alternatives on existing arable land with no further loss of amenity or "wild" land to be considered.
DMJ: See SLF comments.
HE: 2 nd sentence too prescriptive. Projects are likely to utilise existing infrastructure wherever they are located.
RSPB: Disposal of ash from a 'Waste to Energy' plant (Baldovie, Dundee) is a significant environmental problem
With the proximity principle now in place it would seem appropriate for the NPPG to alert authorities to the possible implications of consenting such a facility, specifically in terms of residue disposal and transport generation.
SLC: Looking to guidance on a "suitable urban location"
SLF: Storage of material and waste may have implications on visual amenity.
SRF: Misleading to suggest biomass only takes place in rural areas and energy from waste in urban areas and hence create policy framework prejudiced against, for example, biomass facilities in urban areas, providing heat or heat and power.
WDC: Stated that forestry products and biomass energy plants are suitable for rural locations. Whilst often the plant may look like agricultural buildings the associated traffic, pollution, noise, etc can be significant - suggest that this term be amended to ensure that wider environmental concerns be considered.
RA: EIS must include noise levels from the power station and mitigation measures.
BBL: Larger plants show greater efficiency and these savings outweigh increased transportation costs. Planning authorities should not be led to believe feasible at any scale or that small schemes are preferred to larger ones.
DGC: 2 nd sentence welcomed.
DMJ: See SLF comments.
GCC: Consideration given to need for a Transport Impact Assessment.
HC: Must encourage rail/water rather than road transport
MEGA: Guidance to be more specific about railhead developments - or where development is on forestry land the use of internal haul roads
SLF: LA to be enabler and to pre-plan road upgrades.
SRF: Whilst proximity to the fuel source is likely to reduce transport distances, considerable economies of scale are feasible with larger scale plant and hence higher efficiencies obtained. The focus should be on locating the development in the location with the least overall impact of which traffic movements is one component.
WTS: Welcome developments close as practicable to reduce transportation.
BBL: Planning authorities to be reminded they should not seek to duplicate the roles of other statutory bodies for example SEPA.
GCC: Early consultation recommended - especially concerning level of chimney emissions.
RA: Siting of biomass station needs to take account of the prevailing wind conditions.
RTPI: Greater emphasis on ash disposal.
SEPA: Re-word "Depending on the scale of the activities, processes involving incineration require either an Integrated Pollution Control or a Local Air Pollution Control authorisation from SEPA."
ACC: 2 nd BP In line with the proximity principle, it is suggested that the point includes the statement - "when close to the point of waste production."
AHSS: 2 nd BP Concerned if were to remain in place in current form.
MEGA: 2 nd BP too generalised - fills members with dread - makes life of LA easier if they wish to rubber stamp developments.
RTPI: 1 st BP addresses only rural concerns.
2 nd BP - Simplistic in relation to concerns re waste incineration.
SEPA: 2 nd BP - Waste combustion may not, following assessment of the BPEO be the most suitable means of managing waste. Therefore should be generally viewed as "acceptable". Should provide due regard to the NWS and the emerging AWPs when determining acceptability (see also comment on Para 55 re consolidation.
SNH: Policy needs to be covered by considerations in Paras 55-59.
SRF: Re biomass projects, seems to be less positive statement supporting developments ("should normally be acceptable"), compared to other technologies such as hydro and wind ("should be permitted").
WDC: Very generalised and appears weak when contrasted with other aspects of the NPPG. No mention is given to wider environmental considerations.
CJ: Waste combustion should be seen as separate from biomass as noted in PAN 45.
Notes differences between types of energy plant (combustion and pyrolisis/gasification). Considers the different environmental aspects of these two types of systems needs to be addressed in the NPPG.
DCC: Currently operate a waste to energy plant.
ELC: Guidance to acknowledge that odour may be a public concern.
GCC: Should take advantage of this resource.
HC: Para 61-63 - heading should omit term "waste to energy" as more commonly refers to waste combustion schemes covered under previous heading.
See comment for Para 55.
NLC: Weighting against other types of renewables to be given as may become less significant in long term due to effect of NWS and desire to limit landfill - this should be highlighted.
RTPI: Initial indication of the scope for the use of anaerobic digestion and landfill gas projects would be helpful.
SEPA: "and fit with the National Waste Strategy" included in the last sentence.
WWF: Disagrees that waste to energy can be considered a renewable source. However, guidance appears sensible and is aimed at reducing emissions.
MEGA: SE to insist that new sewage treatment works show how power can be produced in conjunction with sewage digestion.
HC: Greater coverage required in view of future interest. Wave devices can be on/off shore i.e. Islay onshore development. Various impacts should be addressed inc. noise, visual.
MEGA: "Wave power" hardly mentioned. Should re-use of hot water / steam from coastal power stations be considered in terms of renewables / recyclables.
RIAS: Omission of design criteria to reduce visual impact to be addressed.
RICS: DSFB consulted on any potential wave developments in the mouths of rivers.
RSPB: Downplays the potential of wave power in Scotland. The coastal wave power resource in Scotland is among the best in the world. Scotland is uniquely well-placed to become a world leader in the growing wave power sector. Provides little guidance for a wave power projects. Could identify some of the potential issues, as it does for wind, for example, the possible impacts on coastal breeding birds, coastal processes, habitats and species. For offshore wave power regulatory mechanisms remain unclear, can the NPPG clarify this?
Absence of any reference to tidal power is an omission, the impact of tidal barrages can be considerable (for example loss of inter-tidal and saltmarsh areas) and should be identified.
RTPI: Concerned wave energy potential dismissed in such a short space and that no reference is made to offshore wind or to tidal barrages as future, albeit long-term, possibilities. Will be significant onshore implications which the planning system can deal with in the same way as it dealt with the offshore oil and gas developments. Consideration should also now be given to potential future development areas from the point of view of updating national planning policy guidance on coasts and areas for protection.
SCF: Misleading and ignores potential impact. Existing wave generators are located at shoreline rock faces but new technology uses floating arrays which would be anchored offshore and require to distribute the generated power to the grid via shore facilities. Needs elaboration and should include reference to tidal energy, since this would also require shoreside ancillary equipment.
SEPA: Specific guidance included in order to enable development so as to maintain the environmental importance of Scotland's coast.
SNH: Prospects of future bulk electricity generation without significant impacts upon the natural heritage are good for offshore wave power. Justifies programme of investment and incentive for wave power over the course of the next few years. Like to see a supportive message to encourage research and development, and the trailing of new projects for offshore wave energy. New wave developments coming forward are not all requiring onshore coastal locations (2 nd sentence).
SRF: Grid connection points for such offshore devices are likely to be similar in nature to those for seabed cables used extensively around the Scottish islands. A small building or enclosure may be required to house switchgear and other safety equipment. Whilst the design of such buildings should follow normal planning guidelines for new building in the countryside, it should be noted that these would have a specific locational requirement and accordingly might not be subject to the normal constraints on other buildings, particularly given their need to be in a coastal setting.
WWF: Short and provides limited guidance.
BWEA: Strongly supports and that recognition is to be given to role that projects of all size will play in meeting energy needs and climate change targets.
DGC: See comments on NFFO schemes in Scotland.
PR: General commentary on timescales properly associated with planning processes to be added.
RA: Planning system must provide the necessary balance to the promotion of renewables to ensure appropriate development.
SRF: Welcomes size not material in determining its contribution to Government policy. Important in ensuring that smaller scale projects able to play role in meeting climate change commitments.
BWEA: Concerned that makes an ambiguous reference to "amenity standards" being met, though the guidelines do not include any guidance on, or definition of, amenity standards.
The need for environmental assessment should be determined by size and nature of the project and the likelihood of significant impacts, not by whether its grid connected or stand-alone.
DGC: Comments welcomed.
DMJ See SLF comments.
FR: Vast majority of renewables project will be linked to local distribution networks and not the national grid.
HE: Replace "stand-alone" with "smaller". Replace "to be linked" with "needing a major new link" in the final sentence as confusing.
HLP: Do councils have the resources or expertise?
MEGA: Cumulative impact of renewable energy should be addressed and guidance given in development plans.
NWP: Guidance by development plans is most usefully provided by means of specific criteria, rather than mapped locational guidance - concern with maps is that the coarse grain of such guidance cannot take account of different designs of wind farms or issues of local significance. Therefore each proposal in a preferred area would still have to pass through the same detailed scrutiny, whilst a proposal in an area designated as sensitive would have one further obstacle to overcome, in that it could be considered that such a proposal was contrary to the Development Plan. Would support the NPPG6 stating that a proposal should not be considered to contravene the development plan by reason of location alone, but that it would need to contravene one or more specified criteria.
NSW: Support limited information requirements for small developments as will make them more attractive to potential partners.
PE: Ambiguous on whether refers to domestic or 1MW machine.
PR: Good opportunity to re-iterate when guidelines apply. Amend 2 nd sentence as follows "...consistent decision-making in relation to individual applications as detailed in this guidance."
RA: LA coming up with their own location maps will lead to an inconsistent development of renewable energy across Scotland. A guiding national strategy is much more likely to create coherence.
Welcome acknowledgement that smaller projects will not have as large an impact. Propose presumption in favour of supply for regional or local needs.
RDC: Single turbines may be deemed as intrusive. Amend 3 rd sentence to "e.g. single turbines are unlikely to be so significant..."
RSPB: strongly support the use of clearly established criteria to assess renewable energy developments. Believe there is considerable scope for expanding and clarifying criteria to be used.
SLF: Last sentence - will an LA have sufficient expertise. Define "stand alone" as even small schemes can be connected to the grid.
SNH: Developments may be created to serve more than one consumer unit, without being grid-linked. Information sought by local authorities is scale of development and its likely impacts, not whether it is stand-alone or grid-linked.
SRF: Concerned makes ambiguous reference to "amenity standards" being met, though the guidelines do not include any guidance on amenity standards.
Connection to grid not criteria that should determine a different approach. Small project not be expected to perform the full range of environmental assessment that might be appropriate for a larger project. Guidance on break point in Environmental Assessment regulations.
SWLG: Also Para 68-69. Welcome areas being identified in advance - needs extensive consultation with landscape/recreational bodies.
BBL: The preparation of development plans for an area should not be used as a reason for delaying planning applications on current schemes.
BWEA: See SRF comments.
DGC: Relevance of local factors as part of positive framework is welcomed.
DMJ: See SLF comments.
HC: Final sentence unclear - only able to be considered on a case by case basis with LA making a balanced determination
NLC: The principle that renewables should be permitted could seriously weaken the ability of an LA to maximise social and economic benefits of such developments.
NWP: Enabling statements in the third sentence of this paragraph are translated to PAN and to Structure and Local Plans.
RA: Development plans should be drawn up subsequent to the establishment of national and local siting strategies. Policy in this document not be sufficient to ensure that the environmental effect is acceptable.
RC: Also Para 68 = The role of the development plan is not as clear as in existing NPPG.
RTPI: Should be clearer that this paragraph deals with structure plans whereas the following paragraph deals with local plans. If this is the case, the plea for positive provision for renewable energy developments in structure plans is not borne out by the subsequent emphasis on criteria. Proposals with a spatial reference should be required. Otherwise, it is more difficult to expect local plans to safeguard individual sites for future development. Structure plan authorities should be encouraged to identify either preferred or non-preferred areas. NPPGs already provide criteria.
SBC: LA to indicate that development plans should consider formulating technology specific policies appropriate to their area.
Guidance should be given on district heating/CHP.
SLF: "an acceptable environmental effect" difficult to define. LA should be proactive
SNH: Final sentence is important, meaning of the work 'acceptable' is unclear. Suggest revised wording which would give planning authorities a clear steer that a primary aim of policy is to achieve good location, siting and design:
"Planning policies should set out the criteria to be adopted to minimise the impacts of renewable energy developments upon significant elements of the natural heritage, thus enabling renewable developments to take place".
SRF: Support enabling role of development plans
WDC: Concurs that development plans should, where appropriate, identify sites for future development. In particular the Local Plan, which is in essence a land-use document, should identify areas where the opportunity exists for renewable energy developments. Difficult however for a Local Plan to outline the mitigation requirements for a scheme without having detailed knowledge of the proposal - suggests that Local Plans should set out the broad criteria that a developer would require to consider in any development proposal, and that these criteria are not exhaustive but form only part of the assessment process.
Final sentence - considers it is entirely inappropriate for renewable energy to be regarded differently from other forms of development.
Would request that this sentence be deleted from the NPPG or is amended to reflect the situation that other development types possess.
BWEA: Identification of sites for future developments and safeguarding for renewable energy should not, by inference, prejudice the validity of proposals that are brought forward in other areas.
Search or preferred areas should only make planning easier for projects and not introduce additional burdens.
Unclear as to how, within the context of a Structure or Local Plan, it is possible to guide developers on appropriate mitigation for environmental impacts of a project until the details of that project have been assessed and evaluated.
CSCT: Policies in local plans should actively encourage stand alone renewable energy developments at new developments including public buildings, large developments in the countryside or those which lend themselves to "district heating" type systems.
FaC: See safeguarding as onerous. Capacity for an LA to undertake such work is questioned. Possible for SE or others to undertake research and provide detailed guidance.
HC: "criteria" approach for policy preferred, implemented through early discussions with relevant parties - cites Highland Structure Plan 2000.
HLP: Is it possible for policies to guide mitigation?
MEGA: No point in LAs committing themselves to renewable energy if they commit themselves to the use and production of fossil fuels - self-defeating policies.
RA: National and local siting strategies would provide indicative maps of areas where development is acceptable.
RTPI: See Para 67.
SRF: Identification of sites for future developments and safeguarding not prejudice the validity of proposals that are brought forward in other areas.
Unclear how, within the context of a Structure or Local Plan, possible to guide developers on appropriate mitigation until details of project assessed and evaluated.
SNH: Welcome encouragement to identify search areas where development might be most appropriate. Should be clarified that existence of such search areas should not necessarily signify a presumption against renewable development outwith these search areas. Should also provide a guide to the appropriate capacity for development in these areas.
Further sentence should be added to advise planning authorities also to indicate areas or sites where for environmental reasons, renewables proposals are unlikely to be considered acceptable.
BWEA: Do not understand need for specific reference to wind energy within the 2 nd BP.
Welcome in principal the introduction of "preferred" areas for wind power (bullet point 2), would only accept such a policy where it clearly states that such designation does not in any way prejudice projects that are proposed outside those areas - suggest second bullet point is modified to:
"define areas suitable for renewable energy developments, or where appropriate, specific sites in local plans, but not discriminate against proposed developments outside such defined areas".
In requiring Structure Plans to identify sites where development would be "exceptional", this should not add additional burden where the reason for such "exceptional" designation is only as a result of the designation. The authority should be required to justify designation and we suggest that the fourth bullet point should be modified to:
"indicate areas or sites which, after appropriate assessment and wide consultation, it is judged that for overriding environmental reasons proposals for renewable energy development would only be considered acceptable in exceptional circumstances, and to set out clearly the reasons for such restriction".
Believe LA encouraged to consider the contribution that should be made to renewables targets within their area and propose the following additional statement regarding development plan policies:
"In developing structure plans, local authorities should consider the scale and type of renewable energy development likely to be appropriate for the area. In making positive provision for such development, the local authority should take account of national targets for renewable energy development and carbon dioxide reduction and the relative contribution that the area could make given it's resource potential."
EAC: Benefits of stand-alone developments will be taken into account
FC: Identification of preferred areas may be a clumsy and unwieldy policy response, There would possibly be overlapping search areas for different technologies. Preferred areas may be over prescriptive and lead to concentrations of development in particular areas. If done on a sieve map technique greater areas than necessary may be excluded. A criteria based approach supported by the NPPG and other research (the good practice research currently being carried out by the Scottish Executive, the revised survey information and development of the landscape character work) may give a more flexible and enabling framework for the development of renewable resources.
HE: Suggests additional point "recognise the diversity of types of development, including smaller developments".
Worried 2 nd BP will mean "exclude non-defined areas" - refers to SNH study that all landscapes able to accommodate small scale turbine developments.
HLP: 4 th BP Not clear what "exceptional circumstances" are?
HP: Structure plans not to be dictated by SE or one industry - it is for industry to convince local population.
MoC: Para 80 - 82 of NPPG14 recognises need for precautionary principle - guidance should also refer.
2 nd and 3 rd BP - No assistance on how to research or identify search areas, who to involve and what weight is to be given to them. Guiding Principles required before NPPG prepared.
No guidance on comparing a proposal with its benefits to energy supply.
NLC: Appropriate - may be useful to encourage developments such as new housing or business premises to contribute to renewable energy production.
NP: Importance of locational guidance v criteria based is paramount. Have had particular problems even with site that is in a "preferred area for wind energy" - this site would not meet criteria outwith revised NPPG as interpreted by APRS. All current wind farm sites in Scotland outside areas identified in revised NPPG6.
Further research into criteria based approach required taking current wind farms as focus - BWEA and SNH currently developing assessment methodologies re birds and visual impact. Any form of locational guidance stays consider be significant increase in inquiries and appeals.
PR: Pro-active considering locations should reduce the likelihood of time and effort being spent inappropriately.
RA: National and local siting strategies provide a much better framework for evaluation.
RSPB: Unconvinced that 'defining search areas' is either feasible or preferable. For local authorities 'defining search areas' is essentially limited to wind power, could preclude adequate consideration of other technologies. If search areas are simply intended to avoid undue pressure on sensitive sites would support this proposal, however, there is concern that the process of search area selection is lengthy, and quickly becomes outpaced and outdated by technological advances and increased data availability. The converse could be that by selecting specific search areas the industry is pushed into restricted areas thereby leading to issues of cumulative impact.
Would strongly support the application of a tight list of criteria (the bare bones of which appear in Para 19) without necessarily translating this into specific preferred areas on a Key Diagram or proposals map.
4 th BP would appear to provide the ideal solution to this by advising that development plan policies should identify sites where renewable energy projects would only be considered in exceptional circumstances. This could provide the necessary spatial steer by identify areas which should not be considered, or should only be considered in exceptional circumstances, with the criteria for evaluating development being applied in all other areas.
An additional bullet point should be added to this paragraph: 'alert developers to the potential cumulative impacts of renewable energy projects and indicate that this may a limiting factor'.
RTPI: Concerned that, in the absence of a clearer
national spatial strategy, the requirement for development plan policies to define search areas will result in a minimalist approach. Strategically, may make it difficult to meet targets for renewable energy developments. At a local level, it may give rise to problems of cumulative development. Strongly support role of development plans in indicating areas where renewable energy development would only be considered exceptionally and this raises the need, for further guidance on the significance of local designations in relation to renewable energy developments.
SBC: "areas of search" has useful role to play - guidance to provide more explanation of purpose and that it does not provide a presumption in favour of development or exclude such development outwith those areas.
SEPA: Some reference for the need to consult SEPA on specific items in the development plan would be welcomed.
Also benefit from reference to NWS when defining search areas.
SNH: Clarified that areas to be safeguarded for renewables would form part of the search areas. Also helpful to make clear that the search areas, taken together with the areas in which renewables are unlikely to be considered acceptable, are only likely to cover a proportion of an authority's area; there will still be land (possible a majority of the land area) in neither category.
SRF: 2 nd BP Do not understand need for specific reference to wind.
Concerned process of defining "search areas" might lead to creation of presumption against development outwith such areas. Only defined where they make positive provision, hence reducing the level of required environmental assessment and where such areas do not, implicitly or explicitly, prejudice project proposals coming forward outside those defined areas.
Safeguarding of development areas in original NPPG6, have not seen taking place in practice. Is policy practical to implement?
In requiring Structure Plans to identify sites where development would be "exceptional", this should only relate to locations which are not already covered by national, international or other designations - to identify such sites again could lead to doubling the importance of a site or giving undue weight without consideration of the specifics of the project proposal.
WSW: Maps 1 and 2 plus those in development plans highlighting designated sites will facilitate identification of suitable search areas.
ACC: Include consideration for airports and airfields and the need to consult with the Civil Aviation Authority on possible risks.
BBL: There should be a greater distinction re "decommissioning" between wind turbines and other types of renewable schemes which as housed in industrial buildings may be converted to industrial use.
BWEA: Uncertain as to why prominence is given to visual impact and landscape issues, but does not include habitats, species or noise.
DGC: Point 3 - relevant but may be seen as contradicting Para 47.
Welcomes mentioning of decommissioning requirements.
List appears to miss out many of the detailed issues raised in rest of NPPG e.g. pollution, interference, amenity and wider environmental effects.
DMJ: See SLF comments.
HC: Local residential amenity and effects on wider species and habitats to be added to considerations.
MEGA: Why is grid connection so important when Para 47 appears to dismiss partial undergrounding of lines?
PR: Given that Para 47 separates grid connection applications - 3rd BP not necessary.
RICS: Para 70 - 75 May be times when appropriate for developments to be inoperational. LA to work closely with developer when regarding such a period. Overly restrictive timescales would be prescriptive.
RSPB: 5 th BP Amended to include: 'and protected habitats and species outwith these sites', to clearly reflect the policy guidance contained in Paras 19 and 44. An additional bullet point should also be added 'the potential for enhancement of habitats and the requirement for monitoring of impacts', this reflects the advice of NPPG 14.
RTPI: Should start with positive statement with regard to the need to perform a policy led role in the light of this NPPG. The importance of the negotiatory role of development control in securing positive answers through earlier discussions and guidance, mitigation and compensation through revised proposals, planning conditions and planning agreements etc should be emphasised at the outset.
Welcome addition of decommissioning requirements and recommend a further bullet point dealing with habitat enhancement.
SEPA: Requires consultation when any pollution is potentially an issue.
Shall also have a significant role whem developments are to be decommissioned, when applicable.
SLF: Should not only the connection to the grid but also the distance involved be included.
SNH: Purports to be list of factors other than 'environmental and conservation interests'. It reads oddly, then, that list includes 'visual impact and compatibility with the landscape' and 'effect on statutorily designated sites'. List should refer also to impacts upon recreation and amenity, which are not necessarily considered as environmental and conservation interests.
SRF: Unbalanced focus on certain impacts (e.g. landscape and visual) within list and others excluded.
SWLG: Add "impact upon existing uses and activities in the locality."
AHSS: Makes point that development plan is subordinate to the "special regard" to be had for the character of buildings in Section 64 of the Planning (Listed Building and Conservation Area) (Scotland) Act 1997.
NWP: The use of interim policy statements is indicated in this case, see comments on Para 18.
SNH: 'need' for renewables in general may not be a planning issue, but the need for a particular scheme in a particular place will remain an issue.
Suggest "However it will still be for the developer to demonstrate the desirability of a particular scheme in any particular location."
BWEA: 2 nd sentence implies that a project developer is required to answer all and every planning objection, whether these are considered substantive or significant or even valid objections. Like the words "valid and significant" to be included before "planning concerns" at the beginning of this sentence.
The final sentence appears to be misleading. Believe that its intention is to state that due to the government commitments and policies, every renewable energy project has a proven national need, and therefore, the need for the project cannot be questioned. However, this need should be a positive material consideration. This change in emphasis might be achieved by removing the word "not" in the middle of the sentence.
FC: See Para 20.
HLP: Seems to be written from a planning perspective - must also cover Electricity Act applications.
NWP: Last sentence in this paragraph open to misinterpretation - feel that the intention of the draft is that the need for such developments is a major planning consideration, it is the level of output that need not be discussed.
PR: Suggest remove "not" from final sentence given importance SE gives to renewables development.
RTPI: Considers last sentence inappropriate. It is not an issue about need but about the weight given by the policy criteria of the NPPG to factors affecting planning for renewables.
SEPA: Last sentence; concerned that in relation to waste to energy technologies, may undermine the provisions of the NWS.
SRF: 2 nd sentence implies developer required to answer all planning objections, whether these are considered substantive or significant or even valid objections.
Final sentence misleading. Properly state that due to the government commitments and policies, every renewables project has a proven national need, will be a supporting material consideration.
RTPI: Strongly recommend further guidance given with regard to the scope for using planning agreements in relation to the specific circumstances of renewable energy developments, without having to rely on the generalities of Circular 12/1996.
ACC: Removal of obsolete renewable energy structures by section 75 Agreement.
BWEA: See SRF comments.
FR: Issues associated with temporary permissions for a new development and the non-operation of an existing project are separate points, and are best dealt with individually
HC: Use of section 75 agreements in respect of the restoration of a terminated scheme to be mentioned.
MEGA: 2 nd sentence "could" be replaced by "should" to prevent visual dereliction
PH: Developers to post bond in relation to dismantling of development.
RC: Advocate early restoration of redundant sites.
RTPI: Strongly recommend guidance on the use of guarantee bonds in relation to the costs of dismantling and site reinstatement.
SNH: Wording strengthened. LA required to satisfy itself that, should a renewables plant cease to operate, the operator has the resources required and is under a planning obligation to dismantle the development and restore the land to the authority's satisfaction. LA entitled to require a restoration plan and a financial bond to pay for it.
SRF: Concerned any requirement to dismantle only valid where the project owner or operator cannot demonstrate that they are making genuine attempts to ensure operation.
SWL: Crucial that the potential for a project to lay dormant / fail /become uneconomic is addressed, This will reveal the need for conditions or other requirements or mechanisms to ensure that projects are dismantled and land restored. Given the industrialised nature of many developments, the closure or a project should be planned for at the outset, and the landscape reverted to its previous condition.
AHSS: Reject implication that information required for renewables developments must be relaxed.
BWEA: See SRF comments.
DGC: Noted but disappointing that SRO does not support small-scale schemes.
FR: Support the distinction for information requirements on the basis of scale. Small-scale projects can also be commercial.
HC: If hub height exceeds 15 m - needs EIA, cross reference with Paras 26-27 required.
HE: 1 st sentence - delete and replace "Some developments can be on quite a small scale".
2 nd sentence - delete "a small" and replace with "the smallest"
2 nd last sentence - delete "that required.....the grid" and replace with " that required for proposals needing a major new link to the grid"
PE: Replace "can be " with "will be of a much smaller scale".
Does not reflect the alleged "rush" to connect small renewable energy systems to the grid.
Change 1 st sentence to "The size and scale of stand alone or domestic scale grid linked developments...."
Replace with "Consequently.......should be less onerous than that required for large wind turbines"
SRF: Also comments in Para 66, Connection to the grid not be part of criteria for determining the need for environmental assessment as not a true indication of the impact.
AHSS: Only when approved development plans are in place covering these policies should there be a relaxation re notification of developments.
BE: Wind farm interests have had their way - will enable an LA to ignore objectors on larger applications.
BWEA: See SRF comments.
CT: Arbitrary, dictatorial and deprives objectors from making their case.
DGC: Welcomes proposal.
HA: Fully demonstrates unreasonableness of proposals.
HB: Alarmed at proposal - no change to be made.
HP: Notification of new wind farm developments should be based on capacity.
LP: Removal will not attract tourists and neither will wind farms.
MEGA: Notification be reduced to 5 wind farms.
NWP: Welcomed - consider will stream line process..
RC: NID to remain but does not need to be pegged to 10 turbines.
RICS: SE to be kept informed of developments.
RTPI: Appropriate to confirm how the Notification Direction might apply in relation to wind farms in the event of the withdrawal of the Direction relating to ten or more turbines. For example, structures over 12 metres or developments subject to an SNH objection within National Scenic Areas will be subject to notification and developments affecting European designated sites under the Habitats Regulations would also be notifiable.
RTJ: Allows developers an unfair advantage.
SAJ: Result in second chance for objectors to make their case - contrasts right of appeal for developers.
ACC: Map 2 not appear to correlate with the same analysis carried out in the ALTENER report. This identified a larger commercially viable area. Discrepancy requires to be resolved. Indicate a much higher concentration of feasible areas in the north, northeast and islands. Questions policy guidance which focuses development opportunity in or near the central belt.
An area of opportunity that has been omitted from the map is offshore. This is a serious omission given the trends in the industry, which has recognised that winds are far more constant and predictable
APRS: Map 2 of poor quality and at a scale where not helpful. Not worth having unless supports written information.
CC: Larger Map 2 required as scale is too small.
FC: Map in previous NPPG gave Fife a relatively low score; new map using same information indicates potentially greater capacity. Survey update therefore required ASAP.
MC: Map 2 of poor quality - larger scale maps required.
NLC: Map 2 illegible.
NWP: Extraneous lines on Map 2 - believe economic considerations will change and have no material planning relevance.
RJHW: Map 3 should be used to overlay Maps 1 and 2 and will provide information referred to in Para 33.
RSPB: Map 2 - not impressed by quality.
SCF: Map 2, being restricted to the resource available on land, significantly underplays the contribution that the coastal wind resource could play, let alone the offshore resource. A resource map for wave energy would indicate that the West Coast of Scotland has one of the best wave resources in the world. Beneficial if Map 2 included in its key a source of information for details of the offshore wind resource.
SEPA: Clarity of map 1 needs to be improved to be helpful to a LA when defining areas suitable for wind energy developments.
SNH: The word 'suitable' in the last sentence should read 'attractive to commercial developers'. Neither of maps 1 or 2 address environmental suitability.
SRF: Map 1 oversimplifies the electricity network and may cause incorrect conclusions to be drawn about the potential locations for renewable energy projects.
Map 2 would appear to be erroneous in places and not confident that it represents a true representation of the potential wind resource. Given that the technical constraints are likely to change over time, do not feel that such a map is appropriate within the NPPG and might be more appropriate within PAN 45, albeit ensuring full accuracy.
AC: Comments limited due to short time period. Thought revision generally well thought out and a distinct improvement on previous guidance. However fails to address heating with electricity generation and assumes only renewable energy worth producing electricity production. Report outlines intention for further report on grid system in the future.
ACC: Welcomes new guidance.
Too much emphasis on wind power - alternatives include biomass, combined heat and power and offshore energy production, (principally wind, but also wave and tidal). Wants more guidance re offshore developments.
All of these, plus onshore wind power, have significant potential in the North East of Scotland.
Concerned re economic effects on the area by concentrating renewables in southern Scotland.
AEA: Overall well crafted and a positive step to taking renewables into the mainstream.
APRS: Will not adequately equip LA to resolve decisions on large developments - wish to discuss possibility of workshops with SE which they were considering arranging.
Not a balanced message re sustainable development as clearly presumes towards development - SE needs to consider balance between environmental, economic and social issues.
ARIS: Where "built heritage" used may be more appropriate to use "cultural heritage".
Disappointing the relegation of the protection of the 'built heritage' to a position well below that accorded to the natural heritage in this Draft NPPG. Hoped that the opportunity to remedy this in the final version will be taken.
BBL: Support general thrust of consultation paper.
BBS: Generally supported the thrust of the NPPG but were concerned in relation to a number of issues. BBS suggested SE should actively promote renewables; NPPG concentrated too heavily on wind energy and SE should encourage other types of renewables by supporting research and development costs. Also concerned issues re implementation and securing of the effective policy are being passed to LAs. Given SE promotion of renewables, SE bodies should not seek to oppose applications unless can be justified within terms of the NPPG and this needs to be recognised in NPPG.
BEn: Renewables targets challenging and although consideration of planning issues is an important factor in the development of renewable, reducing the technology costs and improving infrastructure are also significant factors that need to be addressed.
CA: Supports policy to reduce greenhouse gas emissions and increase the amount of electricity generated from renewables - however have a duty to develop and maintain an economically viable and sustainable mining industry.
CC: Need for more detailed information to enable meaningful policies and decisions to be made by the LA.
CEA: Sole concern relating to the desire for continuity of electricity supply
CEC: Use of Climate Change Levy to help implement recommendations in guidelines.
CHC: Not supportive of wind farm developments. Comments that an areas power requirements should be co-ordinated..
Does not consider quality of life issues are adequately covered near wind farms and biomass plants.
Energy in versus energy out is not mentioned.
CJ: Pleased continue to see energy from waste as renewable energy.
CKA: Considers that balance between objectors and developers is put too far onto the side of the developers - planning legislation should not be diluted.
CP: Positive endorsement of changes.
CSCT: Support general thrust of the consultation paper.
DGC: Structure plan contains policies which were formed following public consultation. Proposes SE widen consultation to ensure members of the public are aware of changes.
NPPG should provide guidance on use of PV cells in for example conservation areas or on roofs of listed buildings. Does not indicate that SE will provide advice re energy efficiency.
DMJ: See SLF comments.
EAC: Further positive encouragement to individuals to use renewables including grant schemes for capital costs - use in rural areas would promote sustainable energy use
EB: Considers offshore developments would be less intrusive.
ELC: Welcome positive approach but this needs to be balanced with the conservation of environmental resources of a regional or local significance.
EP: Previous guidance basically acceptable - as only people to gain from wind farm are developers, tempted to believe there is collusion.
ERC: Overall principles set out are acceptable and will play important part in facilitating sensitive renewable developments.
Public understanding of renewables needs to be improved - can be achieved through education and publicity, Additionally need to reinforce reduction of energy consumption.
FC: Potential for conflict between increasing levels of renewables and protection of environmental assets. This reflected in public opinion in relation to proposals for small wind farms in East Fife.
No mention of energy efficiency or CHP - believe have an important role to play in he climate change programme.
Para 32 - 64 Additional policy guidelines for individual technologies better addressed in PAN cross-referenced to the NPPG.
FCom: Places too much emphasis on wind power, to the exclusion of adequate treatment of other forms of renewable energy.
Insufficient emphasis on the use of renewable energy sources, to provide heat as opposed to power.
FES: Fully support efforts to encourage appropriately sited renewable energy projects.
FET: No criticism of the guiding principle but looking for larger commitment from SE to renewables.
GCV: Principles put forward acceptable with the attempt to provide balance being laudable, considers some of the text lacks that balance. Wording used runs counter, in some cases, to the wider range of planning and sustainable development objectives being enacted throughout Scotland.
GHP: Recognises wind will play an important part but is of some importance that there is recognition that hydro schemes can also make a significant contribution. Hydro schemes can have a lifetime of 50 years.
GHS: Broadly supports promotion of renewable energy but have some concerns.
HC: Draft "disappointing" and "unlikely to be much assistance". Consider to be "bland and lacks authority" and requires "emboldened" policies. Some of the details should be put in the accompanying PAN leaving the NPPG to concentrate on policy.
Wish to see evidence that a "less protective" scenario is necessary justifying any significant relaxation of policy.
HC's experience was that refusals for applications were undertaken for sound reasons.
The securing of local economic benefits should be encouraged.
Needs to promote "community based" projects.
Wider guidance on planning for energy efficiency required
HE: Welcomes revision. Although definition in Para 2 is useful, rest of NPPG concentrates too much on wind. Considers biomass will become important in near future and NPPG should reflect this.
Suggests NPPG concentrates too much on electricity production and not on processes such as solar and biomass which produce heat.
NPPG needs to highlight and accommodate diverse types of developments which will be stimulated by proposed RSO.
Text re domestic scale developments requires revision.
HLP: Seeking clarification concerning compensation and EIA issues - has previously raised with SE.
HR: Revised NPPG will unfairly stifle debate on wind farm developments.
ICF: Keen current wording not watered down in subsequent drafts.
JD: Disappointingly similar to previous NPPG and would challenge that has "enhanced locational criteria"
Regrettable each LA not set targets or targets for renewables not put in development plans
Missed opportunity on planning for reduction in energy demand. Value in setting target for stabilisation of energy demand.
More info required on the impact of the Utilities Bill.
Distinction needs to be made between SRO and RSO projects
KGB: Document destroys balance between objectors and developers which was found in previous NPPG - object strongly to the proposed revision.
LPA: Supports ethos of guidance and have commented on submission by National Wind Power
MC: Changes arising from new guidance unlikely to be incorporated into subsequent local plans.
McA: Whole purpose to facilitate new wind farms without restrictive constraints resulting from local objections. Provides for democratic deficit.
MCS: Does not place sufficient emphasis on the protection of landscape and other negative impacts - could lead to series of controversial cases that could damage image and public perception of renewables.
Renewables would require some form of energy audit indicating the levels of carbon dioxide emitted during the development of the scheme.
Would like to see more SE commitment re energy conservation.
Would like to see research into small-scale systems and large offshore schemes
MEGA: SE to make positive comment on need to reduce opencast coal production to give more impetus to renewables in Scotland.
MF: Gives impression wind farms preferred. Little interest in local concerns. Might seem large electricity generators were part of drafting committee.
MoC: Concerned at significant shift in policy and could adversely affect environmental quality as highlighted in Para 18 - 19.
NAC: Agrees with general thrust.
NHP: Has seen excerpts of revised guidance - as appears loaded in favour of wind farm developers, opposed in principle
NLC: Agrees with general thrust.
Comments on lack of information or SE lead re solar power.
Guidance relates to large scale schemes and offers little advice or small scale schemes.
NP: NPPG6 should have priority over other guidance to prevent misinterpretation of other NPPGs leading to schemes being thrown out before due consideration.
NSW: Wholehearted support for renewables - no significant concerns with guidance.
NWP: Much to applaud - will serve its enabling purpose, will speed consideration process and save expense.
Want NPPG to provide for more appeals to be taken by written submissions as inquiries tend to rehearse similar arguments.
PA: Questionable and undemocratic document. Developers charter. Wish to be assured that exhaustive and informed debate which developed the DGC structure plan will not be ignored.
PE: Welcomes revision of NPPG.
Oblige energy users to subscribe to renewables - required to purchase green energy locally.
PM: Not supportive of onshore wind farms.
RC: Supportive - but believes NPPG should make a clearer statement that an integrated approach to energy, including energy efficiency, should be developed.
Should consider providing information on policy differences between existing and draft NPPG.
The incremental impact of renewable energy developments should be assessed on a regular basis.
RIAS: LA needs to have clear guidance. Sensitive applications may need expert advice from Royal Fine Art Commission for Scotland.
Training in best practice required or Scotland's "cultural landscape" affected. HS publication on Historical Land Use Assessment may be of use.
Consistent and complete consideration of design issues in all renewable technologies needed in PAN 45 as inconsistent coverage in NPPG6.
Prefer clustering of turbines rather than piecemeal development.
Scope for small systems on offshore islands i.e. Muck.
No reference to energy efficiency.
Importance of upgrading existing buildings to make use of renewables - same presumption in favour should be allowed. Any building for renewables - should be in accordance with best practice in environmental, ecological and sustainable design.
RDC: Concerned over time it takes for development plans to go through the planning system.
Concerned about how in England appeal decisions have given greater weight to landscape issues than reduction in greenhouse gas emissions.
RICS: Hopes raises profile of renewables. Particularly pleased SE states its commitment to ensure planning system takes on a more enabling role. Stand alone developments to be encouraged by SE and LA.
Suggests reduction in planning fee for photovoltaic cells - believe would encourage expansion.
Location of renewables should be left to market conditions.
SE collate and analyse information and produce national register of existing and new developments including details of unsuccessful applications.
Need to promote energy use reduction.
Best practice note provided to LA with advice on appearance, strength and noise of wind generators
RJ: Alarmed consultation would take away many landscape protection safeguards in relation to wind farm developments - tone suggests written by, or in close consultation with a member of that lobby. Encloses information from booklet on wind farms from Country Guardian.
RJHW: Supportive of draft document and clearer statement of policy in support of renewables.
RMrs: Not supportive of wind farms - suggests use of bio-fuels and that SE should concentrate on the domestic sized units.
RTPI: Looking for National Planning Framework for Scotland.
Welcome positive tone in guidance. However, no comments re planning agreements and lists number of concerns re broader matters concerning renewables
No parameters re planning after 2010.
Use of southern Scotland and central belt for development merely pragmatic to availability of grid capacity - lack of clearer spatial guidance will continue to promote decision making by appeal and judicial review.
No way individual structure plan authorities will feel obligated to the targets.
RTS: Undemocratic as biases planning system against local objectors and in favour of central direction and developers.
SAC: Welcomes SE commitment to role of renewables as a contribution to a sustainable environment
SAJ: Not supportive - sees document as undemocratic and irrelevant to Scottish communities.
SBC: Para 32 - 64 should encourage other types of renewables, not just wind including small scale developments.
SCA: Planning system should guard against developments that are detrimental to the aesthetic, social and natural value of landscape and environment.
SCF: Keen to ensure that, in addressing the causes of climate change, due recognition is given to the coast both in the contribution it can make in being the source of renewable energy and also recognising that "the coast" is a landscape which could potentially be spoilt by unsympathetic development.
Considers that a greater emphasis could be placed on the contribution that marine renewables could make without being outside the remit of an NPPG.
Looks forward to contributing to the revised PAN re marine renewable development in due course.
If the recommendation in the recent report by the Royal Commission on Environmental Pollution to reduce emissions of greenhouse gasses by 60% by 2050 is to be achieved then a far greater reliance will need to be placed on renewable energy (of one sort or another) located offshore from the coast. Now is the time to recognise this future in documents such as the NPPG.
SEPA: Early review of PAN 45 required as environmental impacts only dealt with broadly in the guidance. SEPA wishes to contribute to such a review.
SLC: Although talks of balance, comes down in favour of making provision for renewables.
More explicit explanation on what is considered acceptable/unacceptable degree of impact on natural and built heritage.
SLF: Introduction does not really define SE intention to do something positive about moving the production of energy to renewables. Wants to see definition of "greenhouse gas emissions" and a statement of direction to LAs of the vital need to replace "dirty" energy with renewables, where possible.
Little mention of solar, tidal or small scale systems.
SNH: Focuses too much on commercial wind farm developments - more information re offshore and small scale facilities.
Wind farms encouraged within existing/new forestry plantations.
Possibility of developing one large wind farm close to central belt.
"out of sight, out of mind" approach to be resisted..
SE to look into organising a "planning group" with remit to identify potential capacity of renewables and regional distribution.
SRF: Structure and Local Plans will contain, for some time to come, policies that are not supported by NPPG6, urge SE to adopt either 1) require all planning authorities to prepare and adopt an interim Renewable Energy Plan, or 2) ensure that the policies in NPPG6 carry precedence over those in Structure/Local Plans.
Aware that implementation of item (a) could in itself have quite a long lead-time and therefore we primarily seek clarification over the importance of the new NPPG6 in planning terms.
Smaller/domestic projects to be permitted developments
SS: Recognises environmental and health benefits but wishes full account to be taken of local sport and recreation interests when forming development plan policies re renewable energy schemes.
SSE: Expect planning guidance to treat other types of electricity generation equitably. Don't expect positive discrimination.
Development of large renewable generation presence create funding, planning and environmental issues - need to be addressed in a co-ordinated manner if renewables target to be met in an efficient and effective manner.
VJ: Unspoilt countryside is Scotland's main asset - energy conservation would be more beneficial.
WDC: Generally welcoming.
WJM: Considerable improvement on 1994 guidance. Scotland should be seeking to set targets that reflect its geographical position.
Set out criteria rather than locational or map based approach. Criteria adopted at local level.
Would have preferred more information on waste from energy, biomass and wave schemes.
Greater prominence given to small scale schemes - help rural economy without adverse environmental impact .Expand on "significant" which is used regularly.
Research to be done in some of the perceived problems affecting developments.
WM: Wording from wind energy cant with the 1994 version better balanced meaning NPPG6 did not require revision. Objects specifically to emphasis given to on-shore wind. Wind energy least effective and unpredictable - should be looking to conserve energy.
Disregard for countryside with the whole document disregarding landscape protection.
Undermining of local planning strategies - NPPG seeks to ignore local feeling, undemocratic and smacks of central government seeking to impose its way, regardless.
No protection for residents.
WWF: Sensible and constructive and represents significant steps towards the mainstreaming of renewables.
ACC: Re Para 68 - 69 identifying specific sites may place an unrealistic burden in terms of costs and resources on local authorities. Areas of search should be sufficient.
CNES: None considered.
FaC: Staff training and developing expertise and in identifying sites lead to under estimation of implications.
GCC: Resource implications in achieving levels of data acquisition required for search areas. Has bearing on locational v criteria debate.
MC: No resource implications considered.
List of Abbreviations used in the digest
AGLV Area of Great Landscape Value
AWP Area Waste Plan
BP Bullet point
BPEO Best Practical Environmental Option
CAA Civil Aviation Authority
CHP Combined Heat and Power
DETR Department of the Environment, Transport and the Regions
DSFB District Salmon Fishery Board
DTI Department of Trade and Industry
EIA Environmental Impact Assessment
EIS Environmental Impact Statement
EU European Union
LA Local Authority
LBAP Local Biodiversity Action Plan
LCA Landscape Character Assessment
MAFF Ministry of Agriculture, Fisheries and Food
MOD Ministry of Defence
NEL National Engineering Laboratory
NFFO Non-Fossil Fuel Obligation
NGO Non-governmental Organisation
NNR National Nature Reserve
NPPG National Planning Policy Guideline
NSA National Scenic Area
NWS National Waste Strategy
PAN Planning Advice Note
ROS Renewables Obligation (Scotland)
SAC Special Area of Conservation
SE Scottish Executive
SNH Scottish Natural Heritage
SPA Special Protected Area
SRO Scottish Renewables Obligation
SSSI Site of Special Scientific Interest
TCP(S) A 1997 Town and Country Planning (Scotland) Act 1997
UK BAP United Kingdom Biodiversity Action Plan
Alphabetical List of Respondents to the NPPG 6 consultation
ACC Aberdeen City Council
AC Aberdeenshire Council
AEA AEA Technology
AHSS Architectural Heritage Society of Scotland
APRS Association for the Protection of Rural Scotland
ARIA Association of Regional and Island Archaeologists
BBS Biggart Baillie Solicitors
BBL Border Biofuels Ltd
BEn British Energy
BWEA British Wind Energy Association
CP Cairncross Pay, G
CJ Carruthers, John
CEA Cinema Exhibitor's Association
CA Coal Authority
CSCT Central Scotland Countryside Trust
CEC City of Edinburgh Council
CT Choate, T.A.R.
CC Clackmannanshire Council
CG Coltart, G.J.L
CKA Coltart, K (Aberdeen)
CKT Coltart, K (Thornhill)
CNES Comhairle Nan Eilean Siar
CHC Cullingworth, Chris
DGC Dumfries and Galloway Council
DMJ Duncan Miller, J
DCC Dundee City Council
EAC East Ayrshire Council
EDC East Dunbartonshire Council
ELC East Lothian Council
ERC East Renfrewshire Council
EB Edwards, B.J.
EP Edwards, P
FaC Falkirk Council
FC Fife Council
FR First Renewables Ltd
FCom Forestry Commission
FES Friends of the Earth (Scotland)
FET Friends of the Earth (Tayside)
GHP Garbhaig Hydro Power Company Limited
GHS The Garden History Society
GRF Gilbert, R.F.
GCV Glasgow and Clyde Valley Structure Plan Joint Committee
GCC Glasgow City Council
HA Heald, A
HC Highland Council
HLP Highland Light and Power
HIE Highlands and Islands Enterprise
HP Hodgson, Peter
HR Hooker, R
HE Hunter Energy
HB Hyslop, Barbara
ICF Institute of Chartered Foresters
JD Jennings, D
KGB Keep Galloway Beautiful
LEC Lawrence Environmental Consultants
LLTNPIC Loch Lomond and the Trossachs National Park Interim Committee.
LP Loughlin, P.A.
LPA Lowland Planning Associates
McWA McWilliam, A.C
MC Midlothian Council
MEGA Mining + Environment Group Ayrshire
MoC Moray Council
MCS Mountaineering Council of Scotland
MF Murray Flutter, Maj. A
NWP National Wind Power
NP Natural Power
NHP Nicol, Harvey and Pierce
NAC North Ayrshire Council
NLC North Lanarkshire Council
NSW North of Scotland Water Authority
PA Paterson, A
PM Phillips, M
PR Powergen Renewables
PE Proven Engineering
RJHW Raemaekers, Jeremy ECA/Heriot Watt University
RA Ramblers' Association Scotland
RDC Renewable Development Company Ltd
RC Renfrewshire Council
RJ Roberts, John
RMrs Rogerson, Mrs
RIAS Royal Incorporation of Architects in Scotland
RICS Royal Institute of Chartered Surveyors
RTPI Royal Town Planning Institute
RSPB Royal Society for the Protection of Birds Scotland
RTJ Russell T J
RTS Russell T S
RM Ryan, M
SSE Scottish and Southern Energy plc
SBC Scottish Borders Council
SCA Scottish Canoe Association
SCF Scottish Coastal Forum
SEPA Scottish Environment Protection Agency
SNH Scottish Natural Heritage
SLF Scottish Landowners' Federation
SRF Scottish Renewables Forum
SWLG Scottish Wild Land Group
SAJ Smith A J
SAC South Ayrshire Council
SLC South Lanarkshire Council
VJ Vedebrand, J and Tomas, C
WM Watton, M
WDC West Dunbartonshire Council
WSW West of Scotland Water
WTS Woodland Trust Scotland
WWF World Wildlife Fund
WJM Wright, Johnston and Mackenzie