We are calling for all decisions on energy generation infrastructure to be made at local authority level and for energy generation developments to become part of local development plans. We hope communities and individuals will respond to a consultation from the Scottish Government to look at changing the thresholds for these decisions to be made. The deadline is 27 March
The current situation
At the moment any planning application for energy generation above 50MW is decided by Energy Consents Unit (ECU) at the Scottish Government and only those under the threshold are decided at local authority level. In practice this means that the majority of commercial energy projects are not being decided locally and local people are largely excluded from decision making. The developer-led system for energy, where we have a first-come-first-served process, is overwhelming community councils who are asked to look at applications that come in with no overall plan.
The consultation
We have an opportunity to make our voices heard for a new system as the Scottish Government is currently consulting on the thresholds for onshore energy generation decision making. The deadline is not until 27th March so there is time to spread the word to community councils and campaigners and for people to contact their local MSPs and candidates for the Holyrood election about this issue.
What needs to change
We have been speaking to communities about energy infrastructure and the planning system for the past couple of years and similar themes have been coming out about the ECU consenting process which excludes important local elements in the decision making process. Most importantly this is the element of local accountability and local democracy with, even local authorities themselves, having very little say in the consenting. Local communities have even less involvement in some of the most impactful developments that happen in their areas. There is also no spatial planning for energy, unlike for other developments, which means it is impossible to factor in elements like energy demand, existing grid infrastructure, community energy ambitions.
For our Battery Storage and Planning report published in December 2025 we looked at all consents given for BESS in Scotland up to end June 2025, and in detail at all decisions made by ECU and a sample of those taken by local authorities. In this research we found that ECU decisions were not tending to take NPF4 into account, and that many ECU decision disregarded recommended conditions from local authorities.
We are, however, aware that response times may be different between local authority and ECU-led decisions and we would want to ensure that local authorities do not have any less time available for their decision making, if the thresholds change, than ECU would have had.
What we are asking for
One of our conclusions from the report was that all decisions on BESS consenting should be shifted to local authority level and away from ECU. We believe that the argument is just as strong for doing this for all forms of onshore energy.
We are asking that all decisions on planning applications for onshore energy generation and battery storage are made at local authority level. And that onshore energy generation and battery storage are included in Local Development Plans.
One of the key advantages of including energy developments in local development plans is that bodies such as NESO, and, very importantly, communities, as well as other stakeholders, can be consulted on the spatial element of the planning in order to tie up with grid provision, energy demand, local economic and social needs, and community energy aspirations.
Scotland has a plan-led approach to planning and this should also be applied to energy, rather than relying on the current developer-led system.
There is no risk of Scotland losing momentum on energy development and delivery while the changes are made. This is because NESO announced their grid queue prioritisation in December, prioritising connections for only 23% of the grid queue for BESS in Scotland (14% in North Scotland) and prioritising only 24% of onshore wind in the grid queue. This means that all battery and wind developments scheduled for a connection in 2030 and 2035 will already have planning permission, or be well through the planning system already.
Any BESS or onshore wind development entering the planning system now has an absolutely microscopic chance of getting a grid connection in the next 15 years – so we have plenty of time to improve our planning system for energy with no concerns that this puts a spanner in the works of our energy transition.
The advantages of this approach…
It will bring local democracy back into decision making
In current decision making for energy developments over 50MW, local people are largely excluded from decision making. The developer-led system for energy, where we have a first-come-first-served process, is overwhelming community councils who are asked to look at applications that come in with no overall plan.
Bringing all decisions into Local Planning Authorities means that the decision making process becomes more transparent and more accountable to local people and local democracy.
It will bring forward a plan-based approach
Scotland’s planning system is plan-led which means that decisions on planning applications are made according to a Local Plan, which is made up of the Local Development Plan and NPF4, Scotland’s National Planning Framework. The Local Development Plan is a spatial plan which includes homes, roads, areas for business and industrial development, areas for nature conservation, and Green Belts, among other things.
This approach does not, however, include planning for energy developments. The planning regime for energy is not plan-led, as it is for other development, it is developer-led, which has led to the first-come first-served process we have at the moment.
We are proposing that energy developments be included in Local Development Plans, rather than relying on the current developer-led system.
It will ensure decisions look at NPF4 as a whole
Having energy infrastructure consenting as a local planning authority decision will ensure that the principles and policies of National Planning Framework 4 (NPF4) are upheld in the decision making process. NPF4 has nature and climate as overarching principles, and a set of policies covering everything from soils, homes, flooding and play, to tourism, transport and business & industry, and everything in between. The Planning authority
For ECU decisions, NPF4 is a ‘material consideration’ but it is not as central to the decision making for energy developments over 50MW as it is for those below. In practice, where we have looked at decisions in detail – for example at BESS consents in our report on Planning and Battery Storage – we have found ECU is largely disregarding NPF4 policies. We looked particularly at Green Belts and Biodiversity, but it may be consistent across the piece. We have written to the Minister responsible, along with other NGOs in LINK, regarding issues of biodiversity enhancement particularly.
If decisions are taken by Planning Authorities the National Planning Framework will be considered as a whole in decision making, ensuring that the various policies are weighed up and considered and the Local Development Plan is part of the decision making process.
It will ensure local and regional differences can be taken account of in decisions and plans.
This is one of the key advantages – all areas of Scotland are not the same. They have different needs depending on their situation. Local decision making combined with the Local Development Plan process can ensure that energy developments deliver the most benefit for local places. This does not happen with the current system.
It will ensure planning decisions link up with the electricity grid
It will also make an obvious way to involve NESO and planning for the grid as there will be a spatial plan element – at present there is no relationship between the way energy is consented and the planning for the grid. This must change.
It will ensure decisions tie in with other proposals, plans and strategies
The Local Development Plan gives a means by which proposals, plans and strategies within a local authority can be brought together in one place, and where all the relevant stakeholders can have a say. The trade offs can be examined and the win-wins optimised.
It will bring more funding into local planning authorities:
Local Authority planning teams are very under resourced, and this offers a solution to this issue as the fees for applications above 50MW jump up very sharply – from £25,000 under the threshold to £70,000 over the 50MW threshold (see table in consultation response below for full range of figures). At present local authorities only decide on those under the threshold but have to engage on, and comment on, all applications that come in to ECU, even though they are not getting any money from the fees. If they choose to object to to the proposal they then need to pay for a |Public Inquiry, further stretching their budgets. This proposal means that local authorities will benefit from the far larger payments made for developments over 50MW.
Respond to the consultation
You can see our consultation response here:
Threshold for decisions on onshore electricity generation
This is the APRS response to a Scottish Government consultation on increasing the threshold for onshore energy generation applications under The Electricity Act. We want to see all onshore energy applications to be decided at Local Authority level. Response sent 10th February 2026
…..and below
APRS Consultation Response – thresholds for energy decisions
1. Should there be a single threshold applicable to all technologies?
Yes
Please use the text box below to explain your view
2. What threshold should apply for applications for electricity generation to be determined by planning authorities?
50MW 100MW 150MW
Please use the text box below to add any comment in support of your answer
All onshore energy generation including BESS, solar and onshore wind applications should be decided by local authorities to help ensure better local democratic accountability, more balanced decision making and ensure that the whole of NPF4 is more transparently considered in decision making. In England all decisions on BESS are taken by planning authorities at present.
Giving Local Planning authorities the role of decision making on all onshore energy applications would allow decisions to be made democratically at the local level with opportunity for decisions to reflect local sensitivities, priorities and needs. Local communities need to be represented and have a meaningful role in the consenting process, which they do not under ECU processes. This approach would allow for enhanced local democratic input as well as giving better local accountability and increased transparency.
Decision making at local authority level means that NPF4 could be applied more effectively, and with a more spatial dimension. And could prioritise local social and economic effects of development to better benefit local communities.
It would also give the opportunity for energy generation to be included in Local Development plans and for the plan-led system to apply to energy projects, as well as other development.
3. Any change to the threshold would apply only to new applications. Do you have any comments on transitional arrangements?
Please use the text box below to explain your views
4. Do you have any other comments to add?
Please use the text box below to add any comment in support of your answer.
Local Authority Planning teams are very under resourced so the decision making role would need to be accompanied by the payments that are made to ECU at present for their decision making. See below for table of charges
| Construction, or construction and operation, of generating station (depending on capacity) | Fee payable (non-EIA) | Fee payable (EIA) |
|---|---|---|
| <10 MW | £6,500 | £7,000 |
| 10 MW – 50 MW | £25,000 | £35,000 |
| 50 MW – 100 MW | £70,000 | £125,000 |
| 100 MW – 300 MW | £100,000 | £180,000 |
| >300 MW | £150,000 | £280,000 |
Table 1: Fees payable to submit planning permission for BESS of various sizes Source: The Electricity (Applications for Consent and Variation of Consent) (Fees) (Scotland) Regulations 2019
5. Do you have any comments on the partial and draft impact assessments undertaken?
Please use the text box below to add any comment in support of your answer.