NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.


Proposed key objective of NPF4: To have regard to the desirability of preserving peatland so that climate change benefits of reducing emissions and other benefits including to air and water quality, biodiversity and habitat creation and flood alleviation are realised.

The important roles of peatland in storing carbon, maintaining biodiversity and flood mitigation were all highlighted, as was the value of the archaeological and palaeoenvironmental deposits that may be preserved in peatlands.

However, there were differing perspectives on the priority that should be placed on preserving peatlands. Comments on the proposed key objective included both that:

  • The wording should be strengthened so it is a requirement to preserve peatland, rather than just being desirable.
  • The desirability of preserving peatland should carry less weight in NPF4 and should not hinder renewable energy development.

Suggestions for measures that might be taken with respect to policy and guidance on preserving peatland included that:

  • Protecting peatlands should be a National Priority.
  • There should be a presumption against the disturbance and/or removal of peatlands, and that consideration should be given to a moratorium on development on Class 1 peatland.
  • NPF4 should adopt a clear stance on peatland and soil conservation and management, with clear definitions for different peat and soil types. Consistent definitions of peat and carbon rich soils should be used across Government and National Organisations.
  • Different grades of peat should be distinguished, so that healthy eco-systems are distinguished from peatlands that are already degraded. A definition of what constitutes deep peat is needed, and stronger policies are required to prevent development on deep peat.
  • SNH's Peatland Map should be used to inform spatial guidance for onshore wind, and potentially other types of developments.
  • Farmers that have peatland on their land should receive payments for maintaining peatlands.

The importance of spatial strategies and Regional Land Use Plans (RLUPs) in protecting peatland were noted and it was argued that there should be rigorous, independent assessment of all proposed development on peat, using up-to-date guidance.


There was a call for an end to commercial extraction of peat both from viable or restorable peatland and from all peatlands. Extraction of peat for horticulture was highlighted, with an associated suggestion that sale of peat-based composts (including imported material) should cease. It was also argued existing extraction permissions should end, with a specific suggestion that this should happen by 2023. A review of the peat extraction needs of the whisky industry was also suggested.

Although a ban on commercial peat extraction from degraded peatlands was proposed, one Local Authority noted that they would support an approach that allowed peat cutting on already degraded peat areas. Peat cutting for domestic fuel in the Western Isles was also suggested as an exception to a ban on extraction.

It was also argued that practices such as muir burning should be discouraged or phased out.

Development on peatlands

Criteria for development

With respect to development on peatland it was suggested there need to be clear criteria for what is and is not acceptable. Policy guidance on development appropriate on Class 1, 2 and 5 soils was requested in particular.

Criteria suggested for considering development on peatland included:

  • A specific locational need for the development.
  • A small-scale development connected to a rural business.
  • Development for renewable energy generation or mineral extraction which will be fully restored afterwards, and where it can be demonstrated that the adverse impacts on the peatland resource during the construction and operational phases of a development will be minimised.
  • Development that will not result in a net increase in CO2 emissions over its lifetime.

It was suggested that policy on development on peatlands needs to provide some dispensation in the Outer Hebrides, due to the large amount of land covered by peat.

With respect to onshore wind development it was argued the climate emergency requires that significant harm should be demonstrated in order to prevent development that is needed to meet renewable energy targets. It was suggested that many upland peat areas have already been used for commercial purposes such as country sports and commercial forestry and may be degraded habitats to which restoration work brings biodiversity net gain.

Assessing impact

With respect to onshore wind it was suggested carbon losses from development on peat should be assessed using the carbon calculator that has already been developed, and that this requirement should apply to all windfarm proposals, even those under 50MW. Further policy guidance on an acceptable carbon payback periods for windfarm developments was suggested to be necessary.

Points on the working of the carbon calculator included that:

  • Both the calculator and guidance for impact assessment should be updated to capture present understanding of the carbon and ecological significance of peat.
  • The calculator limits the transparency of scrutiny and the ability of third parties to comment quantitatively on wind farm applications and its use in assessing planning applications should be reviewed.

Some means of quantifying the carbon impacts of other types of development on peat was also suggested.

Lack of clear guidance on the assessment of carbon impacts was argued, and the need for clarification of acceptable thresholds and good practice for different development types was suggested. It was proposed that there should be a single Scottish agency responsible for assessment and advice on carbon impacts, and that the assessment of a proposed development in the context of emission reduction targets should constitute a material planning consideration.

Other land types which should be considered for protection

It was suggested it would be appropriate to protect saltmarsh and native woodland due to their ability to both sequester and store carbon.

It was also argued that, while clear guidance should be provided about other land types which could be protected due to their contribution to greenhouse gas emissions reductions, local authorities should decide the level of protection. This was suggested necessary to ensure development is not unreasonably constrained in areas where there is a high percentage of these land types and other carbon rich soils.


Respondents pointed to the importance of restoration of peatlands, with suggestions this should increase and that, where possible, peat forming function should be restored. It was suggested developers should undertake remediation work to badly damaged areas in mitigation of emissions released through development. An Energy Company respondent highlighted the roles that onshore wind developers can play in peatland restoration - noting their own involvement in restoration of blanket bog degraded by drainage for agriculture and commercial forestry plantation. Another suggested it might be possible for large-scale solar PV development on degraded peatland to be designed to support the restoration of that peatland.

It was also suggested that:

  • The mitigation hierarchy should be applied to ensure development minimises impacts in the first instance and that biodiversity net gain to ensure enhancement is delivered.
  • Restoration should be regulated, including because of the potential risk of damage to archaeological features.
  • Sites should have a peatland restoration assessment carried out by SNH and management plans should be prepared for damaged areas.
  • Further guidance on how to restore degraded peat would be useful.



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