By Kelly Wyness, Associate Technical Director, Natural Power
As the draft National Planning Framework 4 (NPF4) is now the subject of public consultation and parliamentary scrutiny until 31 March 2022, we’re turning our attention to paving the way for future plans and supporting clients to adopt good practice when it comes to securing consent for new renewable energy projects by supporting with early-stage intervention that will help inform project design from the outset.
If adopted, NPF4 will dictate the Scottish Government’s priorities and policies for the planning system and how our approach to planning and development will help to achieve a net zero, sustainable Scotland by 2045.
To quote Tom Arthur MSP, Minister for Public Finance, Planning and Community Wealth: “The challenges that we are facing today demand a change in the way we plan our places for tomorrow. As we recover from the pandemic, we have an opportunity to work towards net zero in a way which also tackles longstanding challenges and inequalities. We will need to future-proof places, be more innovative, and involve a wider range of people in planning. A shared spatial strategy can enable the investment and development that we will need, but we must do this in a way that benefits business and communities, our health and wellbeing and the environment. This will require us all to work collectively to ensure that decisions we make today are in the long-term public interest.”
From my perspective, there are two areas of particular interest in the framework. Policy 13 – Flood Risk, and Policy 33 – Soils.
Policy 13 highlights that “Developments should not be supported within the Future Functional Floodplain.” Essential infrastructure, which includes renewable energy installations, is an exception, but project developers are likely going to have to demonstrate that flood risk is assessed and mitigated for development proposals.
Local development plans should strengthen community resilience to the current and future impacts of climate change, including identifying opportunities to implement natural flood risk management and blue green infrastructure. Furthermore, plans should take into account the probability of flooding from all sources, and consideration should be given to flood-resistant and resilient materials and construction methods to ensure the ability to make future adaptations to accommodate the effects of climate change can be demonstrated.
Development proposals which create, expand or enhance opportunities for natural flood risk management and blue-green infrastructure should be supported. Working with forward thinking clients, Natural Power is at the forefront of integrating natural flood management solutions into development proposals that not only reduce the risk of flooding but provide additional biodiversity benefits and support carbon sequestration.
It is also worth highlighting Policy 33 which covers soils. The policy seems to be favourable for wind farm sites to be located on peatland, regardless of classification, if impacts on peat are appropriately assessed and restoration is considered. Proposals must include detailed assessments for managing the risk to this resource as well as demonstrating an understanding of the depth, conditions and stability of the peat and peatland to help inform the placement of infrastructure.
An established and accepted level of survey, assessment and reporting is already undertaken to support the development of projects. This clearly highlights the efforts undertaken by the renewable energy industry, at a site-specific level, to support the appropriate siting of infrastructure and development of mitigation and enhancement measures. This is highlighted in this peat guidance document that Natural Power co-authored last year with Marcus Trinick QC, Dr Andy Mills at East Point Geo and Dr Kate Massey of Alba Ecology, “Carbon-rich soils, deep peat and priority peatland habitat: expert views on project level assessment document: www.naturalpower.com/uk/news/news-post/industry-leading-peat-guidance-for-wind-farm-applications-co-authored-by-natural-power
As stated in the foreword, the discussion document brings together the collective knowledge of an experienced group of industry professionals working across the peatland EIA topics. It is intended to summarise the industry’s current approach to and understanding of peat habitat, peat soil and carbon assessment in support of wind farm applications.
Degraded peatlands emit more carbon than they remove and thus become a net source of greenhouse gases. With the planned scale for renewable energy development over the next 10 years the sector, working with the Scottish Government, has the potential to offer significant opportunities for peatland restoration at a scale that can help meet the 2030 75% reduction targets. It also worth highlighting that if considered accordingly, the potential opportunity and scale of restoration also can also support Policy 13 in the creation, expansion or enhancement of natural flood management.
Whilst there is plenty to think about, NPF4 is a positive move in the right direction for renewable energy projects. It recognises the vital work already underway by industry professionals whilst providing developers with a clear pathway, and undoubtedly, will make it easier to secure planning consent if the guidance is followed by providing a transparent framework for local authorities.