Comment

Year of COP26: A focus on Scotland and the climate emergency

With the UN Climate Change Conference of Parties (COP26) taking place in Glasgow this year, we’re kicking off our series on what we can expect from the green energy sector, and the work being undertaken across each of the UK countries, starting with a focus on Scotland. Below we summarise the latest Scottish position, what is expected in 2021 and our asks of the Scottish Government.

The latest position

Climate Change Plan 

The update to the Climate Change Plan (16 December 2020) provides a route for a green recovery from COVID-19 via net zero. This plan confirms how the Paris Agreement targets can be met by Scotland, recognising the role of a flexible and responsive energy system, a support framework for emerging technologies and a commitment to securing faster planning decisions for renewable energy development. It also recognises the role of commercial companies in the generation, supply and storage of renewable energy.

NPF4 Position Statement

The position statement (16 November 2020) sets out the direction of travel for the emerging NPF4, recognising the declared climate emergency by raising its status to a material planning consideration in the determination of applications and the preparation of development plans. Moves to revisit the spatial framework for onshore wind, with potentially less restrictions, are set out and welcomed. It also acknowledges a need to address new technologies and strategic issues such as grid improvements in the final NPF4 document.

Revised Scottish Planning Policy statement (SPP) 2020 - (December 2020)

This includes changes to paragraphs which are relevant to energy. These changes relate to the presumption in favour of sustainable development and confirm that this does not negate the requirement to accord with the development plan unless material considerations indicate otherwise. It confirms that where a development is sustainable, that in itself will be in its favour.

Hydrogen Policy Statement (HPS)

The HPS (21 December 2020) sets out the Scottish Government’s aspirations to establish and build upon hydrogen production to meet domestic demand, with a target of generating 5GW by 2030 and to be an exporter of both blue and green hydrogen to Europe. This clearly sets out the aims for this emerging market, and has sought to set early targets to provide confidence to companies and developers who are looking towards this technology, which has significant application across existing and new businesses.

Scotland’s Energy Strategy Position Statement (March 2021)

The Statement sets out how the Scottish Government intends to build upon the recent Programme for Government to focus on addressing climate change and COVID-19 recovery. It recognises the achievement of Scotland in reaching a 50% reduction (from 1990) of greenhouse gas emissions. It follows the recent Climate Change Plan Update which sets out the pathway to 2032 targets and includes policies further to the 2018 Climate Change Plan. It also sets out the pathway toward net zero ahead of COP 26, particularly the requirement for a refresh of the Onshore Wind Policy Statement ahead of COP26.

It emphasises the continued commitment to supporting renewables developments in the right places to help meet net zero targets, and the continued growth of Scotland’s renewable energy industry which is fundamental to creating sustainable jobs.

Bioenergy progress update (March 2021)

A Bioenergy update was published by the Scottish Government in early 2021 confirming that an expert working group has been set up to research and prepare a Bioenergy Action Plan by 2023.  This will identify the role of Bioenergy in delivering net zero carbon, taking into consideration the competing demands on land for feed stock production, sustainability, technical capabilities and opportunities of a just transition to net zero.

What else is expected in 2021?

Scotland’s Fourth National Planning Framework (NPF4)

The principle aim of the emerging NPF4 is addressing climate change, acknowledging this as a material consideration in development plans and the determination of applications. Once published, NPF4 will form part of the development plan against which planning applications must have due consideration and will have equal weight to up-to-date policies of local development plans.

Consultation on the NPF4 position statement (see above), closed on 19 February 2021. Further engagement will culminate in the publication of the draft NPF4 in autumn 2021. This will include policies, spatial strategies and the proposed national developments.

Regional Spatial Strategies

Following publication of the Planning (Scotland) Act 2019, Strategic Development Plans are in the process of being replaced by Regional Spatial Strategies (RSS), with most using the pre-existing evidence base to calculate demands and spatial strategies for energy infrastructure. Given the importance which the Scottish Government attaches to addressing climate change, and its significance as a material consideration, we can expect to see RSS setting targets for the delivery of energy infrastructure at a regional level with transition into local development plans in the future.

Our asks: up-scaling and commitment

1. Confirmation of the significant up-scaling of renewable energy in order to secure net zero, which needs to be reflected in the emerging new Scottish Planning System.  

2. The early publication of NPF4, which contains:

• a simplified policy for renewal and repowering existing onshore schemes;
• a clear focus on the need for assessment of renewable energy to focus on the balance between addressing the climate change and environmental impacts; and
• a shift to protecting only the most important of designations and recognise grid improvements as a national development priority.

3. Clear commitments and a route map for delivery of all existing and new emerging technologies. In recognition that the planning system can be slow to react to emerging technologies, the proposed consultation and working group on emerging technologies is welcomed, but this group needs to have a strong focused remit, to ensure that Scotland can harness the potential of emerging technologies. This should include online energy planning guidance which is updated regularly.

4. Culture change throughout the Scottish Planning System. A move from over-complicated and restrictive energy policies, which are inconsistent from one planning authority to another, to national level energy policies which demonstrate the weight and importance of addressing the climate emergency, and promote the necessary significant number of new energy developments required in Scotland.

For more information on the climate emergency, green energy or our work in Scotland please contact Lisa Russell.

12 July 2021