Chapter 3: Environmental Considerations: Achieving Balance and Maximising Benefits
3.1.1. The Scottish Government is committed to ensuring Scotland's citizens have access to affordable, low carbon and renewable energy whilst tackling the climate and nature crises in tandem.
3.1.2. Our net zero journey is multi-faceted and no single technology or approach will allow us to meet our challenging deployment ambitions. We must achieve a balance to ensure that we maximise both the environmental and economic benefits to Scotland.
3.2. Shared Land Use
3.2.1. The economic value of Scotland's natural capital is significant. In 2018, the value of Scottish natural capital was £206 billion, equivalent to 17% of the UK asset valuation. The Scottish Government is committed to a "four capitals" approach to economic recovery. This means placing natural capital on an equal and interlinked footing with social, economic and human capital, to help build a stronger, more resilient wellbeing economy. Nature-based solutions, like peatland restoration, provide ways to target investment in the right types of natural capital in the right places.
3.2.2. In May 2020 the Scottish Government published Scotland's Environment Strategy which creates an overarching framework for Scotland's strategies and plans on the environment and climate change. These set out our long-term ambitions for Scotland's natural environment and our role in tackling the global climate and nature crises. The Continuity Act placed the strategy on a statutory footing by requiring Scottish Ministers to prepare an 'environment policy strategy' and to submit annual progress reports to Parliament until it is published. The first report was published in March 2022 and is available on the Scottish Government website here.
3.2.3. We are aware of the varying demands on land in Scotland and that a balance must be struck to best serve our net zero ambitions. Our Land Use Strategy, published in March 2021 stated:
"Our land contributes to climate change mitigation in many ways. Scotland has a long and positive history of harnessing renewable energy and our capacity to generate it will need to be increased to meet our net zero targets. Our energy will continue to be provided by a wide and diverse range of renewable technologies, including onshore wind. We will need to continue to develop wind farms, in the right places, and also look to the extension and replacement of existing sites. As set out in our Onshore Wind Policy Statement, in order to achieve this developers and communities will need to work together to ensure that projects strike the right balance between environmental impacts, local support, benefit, and – where possible – economic benefits for communities, for example through community ownership or other means... "
3.2.4. As Scotland moves towards a net zero economy there will need to be significant land use change from current uses to forestry and peatland restoration. This needs to happen alongside ensuring space for other essential activities such as food production, renewable energy generation, including onshore wind, and the protection and enhancement of habitats and biodiversity.
3.2.5. Our statutory and environmental consultees will continue to play a crucial role in assessing this balance for all onshore wind planning applications. The onshore wind sector must continue to build on their positive relationship with the statutory bodies, engaging as early in their considerations as possible, and building upon the existing collaborative approach through the design and development of sites.
3.3. Peat and Carbon-Rich Soils
3.3.1. Scotland has over 2 million hectares of peatland, equating to approximately one third of its land area, and our peatlands are of national and global significance. In good condition, peatlands provide multiple benefits: capturing and storing carbon, supporting nature, reducing flood risk, cleaning the water that feeds burns and lochs, and providing places for leisure that can support health and wellbeing. However, around 75% of our peatlands are degraded through drainage, extraction, overgrazing, burning, afforestation and development.
3.3.2. Degraded peat offers fewer benefits and becomes a net emitter of greenhouse gases and accounts for around 15% of Scotland's total net emissions. Reversing degradation through peatland restoration is therefore central to mitigating and adapting to the linked climate and nature crises.
3.3.3. Our Climate Change Plan update set a target to restore 250,000 hectares of degraded peatland by 2030. Our £250 million funding package is directly supporting this and will leverage additional private finance. This investment will support good, green jobs in the rural economy and play a part in Scotland's just transition to net zero by 2045.
3.3.4. Against our target to restore 250,000 hectares by 2030, we have delivered 57,500 hectares to date at an average annual rate of 5,700 hectares in recent years. This is below our annual goal of at least 20,000 hectares, and there are many reasons for this, not least that peatland restoration is a sector in its infancy and is building delivery capacity.
3.3.5. The Scottish Government-led Peatland Programme is driving action to address the many barriers to increase restoration rates in order to meet both current and future targets. This includes actions to boost supply and demand, increase private finance, incorporate peatland interests in other policy areas and acquire new evidence to support decision making.
3.3.6. The continued deployment of onshore wind and restoration of peatlands and carbon-rich soil will both play vital roles in delivering Scotland's emissions reductions targets, as stated in the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. It is imperative that we strike the right balance in how we care for and use our land. Given the established need for additional onshore wind turbines to tackle climate change and to ensure long-term availability of cheap, renewable energy, in some cases it may be necessary to construct onshore wind farms on areas of peat.
3.3.7. We recognise, however, that the peatland impacts of onshore wind farms can be significant and we must balance the benefits from onshore wind deployment and the impacts on our carbon rich habitats. This includes being aware that there is potential for development in an area of deep peat to have a net negative carbon impact. We therefore commit to the following actions:
- Work is underway to assess the operation of, and if necessary update or replace, the carbon calculator. The Scottish Government will ensure that adequate tools and guidance are available to inform the assessment of net carbon impacts of development proposals on peatlands and other rich carbon soils.
- We will convene an expert group, including representatives from industry, agencies and academia. This will provide advice to the Scottish Government on how guidance could be developed to support both our peatland and onshore wind aims.
3.3.8. Overall, the onshore wind sector in Scotland has made remarkable advances over the past decade in mitigation and restoration solutions for peatland, with environmental agencies and the renewables sector working together to update the good practice guidance for the construction of wind farms in 2019. In addition, Scottish Renewables have considered this issue and published their Wind Power and Peatland: Enhancing Unique Habitats which aims to promote best practice across the sector.
3.3.9. Scotland's onshore wind sector can bring many and considerable benefits to rural areas, ranging from the delivery of jobs and investment to the restoration and protection of natural habitats. The Scottish Government wants to see the onshore wind sector continuing to contribute to peatland restoration as part of development and expects the sector to step up to the challenge of biodiversity loss by showcasing considered schemes that will not just mitigate impact but also improve and enhance our natural environment.
3.3.10. To take just one example, Clyde Wind Farm is an established wind farm within the landscape and has the benefit of seeing the initial results from these peatland restoration and biodiversity improvement programmes. Their experiences and lessons learned are detailed in Annex 1.
3.3.11. We consider the identification of the condition of existing peatland to be a vital part of the wind farm design process. It is crucial that all developers engage in an open dialogue with land management as early as possible, ensuring that appropriate, site-specific solutions can be deployed through habitat and land management plans. Bespoke management plans should incorporate industry-wide advances in thinking as well as site-specific knowledge to ensure the optimum outcome; where pristine peat is protected, and degraded peat is restored and/or enhanced.
3.3.12. The variety of measures that can be included within wind farm design to improve degraded peatland have continuously developed as the industry has matured. Peatland restoration and enhancement, developed in tandem with improving habitats for important and protected species, allows projects to deliver multiple positive benefits to biodiversity and the natural environment. These measures should be further enhanced through ongoing monitoring to ensure the efficacy of the actions undertaken, and iterative improvements should therefore be expected.
3.3.13. By assessing the net carbon impacts of proposed developments on carbon-rich soils and peatlands we will ensure that planning and consenting regimes result in the right projects in the right places, with all applications considered on a case-by-case basis within the relevant planning regime.
3.4.1. In February 2019 the Scottish Government published Scotland's Forest Strategy, covering the decade from 2019 to 2029. This presented a long-term framework for the expansion and sustainable management of Scotland's forests and woodland. It specifically noted the role of Scotland's forests in climate change mitigation and in achieving the targets set out in the Paris Agreement.
3.4.2. Creating new forests and woodlands is an important tool for reducing greenhouse gas emissions. For each hectare of forest and woodland created, it is estimated that, on average, seven tonnes of CO2 will be removed from the atmosphere each year. The Climate Change Plan includes a commitment to increase forest and woodland cover in Scotland from around 19% now, to 21% by 2032, and our 2020 update to the Climate Change Plan set out ambitious targets to incrementally increase woodland creation from 12,000 hectares per year in 2020/21, up to 18,000 hectares per year by 2024/2025.
3.4.3. While our ambitious woodland creation targets will help deliver additional carbon reductions, the existing resource must also be managed sustainably to preserve Scotland's carbon sink and the many other benefits and ecosystem services that woodlands provide. These benefits can include positive biodiversity impacts, flood mitigation, people's health and wellbeing, and supporting the economy by providing jobs and timber to meet our needs.
3.4.4. Protection of existing forestry, as well as expansion, is integral to our climate change targets. Woodland removal should be kept to a minimum and where woodland is felled it should be replanted. These aspects of Scottish Government policy, detailed through the Control of Woodland Removal Policy have formed part of the considerations for relevant onshore wind developments for more than a decade. This proves that the protection of forestry and the promotion of onshore wind already co-exist.
3.4.5. The Scottish Government recognises that net zero cannot be attained without a considered balance of land use. Our ambitions for forestry and onshore wind can complement each other, and there are many good examples of sites supporting both land uses.
3.4.6. Through consultation for the draft Onshore Wind Policy Statement (2021) we asked for views on the integration of taller turbines in forested areas. What would previously have been considered "taller" turbines are now more common and must continue to be deployed in appropriate locations. The "keyholing" technique, where a small area of forestry directly surrounding turbines is removed, thus preventing the need for clear-felling, is one manner of achieving such integration and one which many consultation respondents considered a "sensible solution".
3.4.7. Taller turbines have a higher installed capacity which results in the need for fewer turbines per site. This, alongside the ongoing commitment to compensatory planting, will allow the Scottish Government commitments to both onshore wind development and re-forestation to continue to complement one another.
3.4.8. However, the Scottish Government recognises that the successful integration of turbines and forestry will depend on the unique attributes of each site. Developers must continue to engage with Scottish Forestry and with local Forestry and Woodland Strategies and ensure that careful siting and design minimises impacts on woodland and integrates enhancement measures where relevant.
3.5.1. Securing positive effects for biodiversity is one of six statutory outcomes for our fourth National Planning Framework (NPF4). Delivering both our emissions reduction targets and our wider national priorities for the environment and land use will require us to conserve and enhance biodiversity, protect and restore habitats and species populations while generating enough green electricity to support our economy and the decarbonisation of currently carbon-intensive sectors. Delivering these outcomes will support the achievement of our net zero and nature ambitions.
3.5.2. The Climate Change Plan update describes an ambition to develop thriving economies based around woodland creation, peatland restoration and biodiversity as well as sustainable tourism, food and drink and energy generation.
3.5.3. The Scottish Government published a consultation on a new Scottish Biodiversity Strategy on 20 June 2022 and consultation ran until September 2022. This draft strategy set out the evidence of biodiversity loss, and its links to climate change, alongside Ministers' high-level goals for biodiversity in Scotland: to halt biodiversity loss by 2030 and substantially restore biodiversity by 2045.
3.5.4. The Biodiversity Strategy will be supported by a series of adaptive, dynamic Delivery Plans which will set out the actions needed to achieve the ambition in the Strategy and detail Scotland's commitment and ambition for the recovery and restoration of biodiversity in Scotland. The new strategic framework for biodiversity, incorporating the Strategy to 2045 and Delivery Plan, is expected to be published in Summer 2023. The framework also includes our new Natural Environment Bill which will establish statutory targets for nature recovery for the first time in Scotland.
3.5.5. Wind Europe published 'The Role of Wind Energy in Wildlife Conservation' in 2017, and SEPA and NatureScot have also published detailed guidance on the design and management of wind energy sites so that they can be properly sited in the landscape and make a positive contribution to delivering the ambitions of the Biodiversity Strategy. The overarching aim is to enable the protection and restoration of local biodiversity, ensuring that wind energy can be deployed in harmony with, rather than at detriment to, the essential protection and regeneration of our natural environment.
3.5.6. Onshore wind will remain an essential part of our energy mix and climate change mitigation efforts, and the resolution of the balance between its deployment and biodiversity interests requires careful discussion and planning at a local level. As the rate of onshore wind deployment increases in the coming years, we see a great opportunity for wind energy developments to further contribute significantly to our biodiversity ambition. By proactively managing intact habitats and the species they support, restoring degraded areas and improving connectivity between nature-rich areas, onshore wind projects will contribute to our climate change targets and help address the biodiversity crisis.
3.5.7. Evidence shows that significant positive effects for biodiversity from wind farm developments can be achieved and examples of best practice of onshore wind developers enhancing biodiversity on their sites is available at Annex 1. We expect all developers to draw from these best practice examples and demonstrate a clear commitment to protecting and restoring habitats.
3.6. Landscape & Visual Amenity and National Planning Framework 4 (NPF4)
3.6.1. Meeting our climate targets will require a rapid transformation across all sectors of our economy and society. This means ensuring the right development happens in the right place. Meeting the ambition of a minimum installed capacity of 20 GW of onshore wind in Scotland by 2030 will require taller and more efficient turbines. This will change the landscape.
3.6.2. We laid our Revised Draft National Planning Framework 4 (NPF4) in the Scottish Parliament on 8 November, signalling support for all forms of renewable, low-carbon and zero emission technologies, and making clear that LDPs should seek to realise their area's full potential for electricity and heat from renewable, low carbon and zero emission sources. The only areas where wind energy is not supported are National Parks and National Scenic Areas. Outside of these areas, the criteria for assessing proposals have been updated, including stronger weight being afforded to the contribution of the development to the climate emergency, as well as community benefits.
3.6.3. Our Revised Draft NPF4 recognises that significant landscape and visual impacts are to be expected for some forms of renewable energy, and makes clear that where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered to be acceptable.
3.6.4. Subject to parliamentary approval, and adoption by Scottish Ministers, NPF4 will form a part of the statutory development plan meaning its provisions will be directly applied in local development planning and decisions on planning applications.
3.6.5. Landscape Sensitivity Studies (LSS) are strategic appraisals of the relative sensitivity of landscapes to development types or land use changes. They are a tool to help guide development to less sensitive locations. These studies can inform a proposal's Landscape and Visual Impact assessment (LVIA).
3.6.6. However, LSS should not be used in isolation to determine the acceptability of a development type in landscape terms and do not replace the need for individual LVIAs and/or Environmental Assessments for individual proposals, however they will continue to be a useful tool in assessing the specific sensitivities within an area.
3.7.1. 'The Assessment and Rating of Noise from Wind Farms' (Final Report, Sept 1996, DTI), (ETSU-R-97) provides the framework for the measurement of wind turbine noise, and all applicants are required to follow the framework and use it to assess and rate noise from wind energy developments.
3.7.2. The Institute of Acoustics (IOA) Good Practice Guide to the Application of ETSU-R-97 for the Assessment and Rating of Wind Turbine Noise was published in May 2013 to support the use of ETSU-R-97 when designing potential windfarm schemes, and the monitoring of noise levels from generating sites. The Scottish Government recognises this guide as a useful tool which developers can use in conjunction with ETSU-R-97.
3.7.3. The Scottish Government is aware that the UK Government has been considering the extent to which ESTU-R-97 may require updating to ensure it is aligned with the potential effects from more modern turbines. The Scottish Government supports this work and we anticipate the results of a short-term review project in due course.
3.7.4. Until such time as new guidance is produced, ETSU-R-97 should continue to be followed by applicants and used to assess and rate noise from wind energy developments.
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