APRS Resources

Energy, landscape and planning FAQs

As Scotland moves towards a more sustainable, net zero energy system, where we place renewable energy infrastructure and how communities are involved is really important. We have prepared some answers to questions we are often asked on this subject below.

The full webpage for these frequently asked questions can be found here.

An energy development is being proposed in my area. Who will make the decision about this?

Energy policy is a reserved matter so is set by the UK Government, but proposals for energy-related development fall within the planning system, which is devolved. In Scotland the capacity of the proposed development determines which authority considers the planning application. 

Decisions on developments under 50MW will be made by the relevant local authority via the the normal town and country planning system, while developments in excess of 50MW will be considered by Scottish Ministers and administered by the Energy Consents Unit (ECU) of the Scottish Government. This is the case regardless of the type of development (ie. whether it is for wind, solar, hydro or battery storage developments). Applications for the installation of certain overhead electric lines and associated infrastructure; applications for necessary wayleaves to confer rights over land to install electric lines; and compulsory purchase orders promoted under the Electricity Act 1989 are also made by Scottish Ministers. 

Local authorities are statutory consultees on energy decisions made by the ECU, meaning they must be asked for their opinion on proposed developments. As such, they can be contacted with any concerns or comments on proposed developments, which may impact their overall opinion. 

What must be taken into account when making these decisions?

One of the most important documents in energy development planning is the National Planning Framework 4 (NPF4). While this document contains several policies particularly relevant to energy developments, the Scottish Government has emphasised that the document must be read as a whole, rather than focusing on any one specific policy. So, if an NPF4 policy says a development will be supported under certain conditions, it must still be weighed against other policies which might not give support.

NPF4 also includes 18 National Developments, which are developments of national importance, the majority of which either consist of developing energy infrastructure on a Scotland wide basis, or may involve some energy industry development or uses in more mixed development of specified sites . Details of these can be found in Annex B of NPF4.

Local development plans (LDPs) can also be important in siteing developments, but energy development proposals are not restricted to sites identified for them in the LDP. For instance, NPF4 policy allows that renewable energy developments can (if appropriate in other ways) be built on land designated in the LDP as green belt. LDPs tend to be more important for indicating where energy developments should be sited, rather than where they should not ).

Responses to planning applications can also influence whether a development is built and can help to raise local concerns or highlight local knowledge as to why a proposed site may or may not be suitable for development. These are more persuasive when based on material considerations, which could include a lack of alignment with planning policies or laws, anticipating a negative impact on a conservation area, impacting environmental health, or being similar to other rejected developments in an area. Planning Democracy has prepared a useful general guide for responding to planning applications.

Scottish Government energy targets and the Scottish Government’s Energy and Just Transition Strategy will also be a consideration when published. A draft of the strategy can be seen here

A full library of guidance, policies and strategies relating to energy development planning can be found here

An energy development is being proposed on my local green belt. Is this allowed?

Under NPF4, renewable energy developments are one of the few types of development that will be supported on land designated as green belt in the local development plan. However, the development must meet certain criteria, such as reasons being given as to why the development cannot be located outwith the green belt, the proposal being compatible with the surrounding landscape character, and there being no significant long-term impacts on the surrounding environmental quality of the green belt. They must also meet the conditions laid out in Policy 11 of NPF4, which deals with energy. Should the site where the development is proposed include other environmental features, such as woodland or peatland, the relevant NPF4 policies must also be taken into account. 

Consents for some energy proposals, with the exception of wind farms, can also be time-limited, after which the green belt designation should theoretically remain if it has not been changed in the Local Development Plan. If a development is proposed on your green belt, you can ask your local authority about its proposed time scale, and whether any soil and ecological restoration plans have been made for the area following this.

Can energy developments be built on high-quality agricultural land?

Prime agricultural land is defined by its capability for agriculture, as outlined on the Scotland’s soils website. NPF4 considers land of class 1, 2, and 3.1 to be prime agricultural land. A map of each soil type can be found on this website.

Policy 5b) of NPF4 primarily deals with high quality agricultural soils. This policy reads:

“Development proposals on prime agricultural land, or land of lesser quality that is culturally or locally important for primary use, as identified by the LDP, will only be supported where it is for: 

i. Essential infrastructure and there is a specific locational need and no other suitable site; 

ii. Small-scale development directly linked to a rural business, farm or croft or for essential workers for the rural business to be able to live onsite; 

iii. The development of production and processing facilities associated with the land produce where no other local site is suitable; 

iv. The generation of energy from renewable sources or the extraction of minerals and there is secure provision for restoration; and 

In all of the above exceptions, the layout and design of the proposal minimises the amount of protected land that is required.”

NPF 4 Policy on Agriculture

As such, NPF4 allows for energy developments on prime agricultural land where there is provision for restoration of the soil and where the design of the proposal minimises the amount of protected land required and restoration plans are put in place. Proposals for most energy developments, with the exception of wind farms, can be time limited, so your local authority should be able to tell you how long the development will be on a given site. 

Can energy developments be built in protected landscapes or areas with a landscape designation?

General advice regarding landscape designations:

Proposed wind farms must assess the cumulative effect of the development on any relevant wild land and landscape designations. More information on this can be found through the NatureScot guidance on addressing cumulative impacts of wind farms. 

Virtually all local authority areas, alongside NatureScot, are required to prepare Landscape Sensitivity Assessments to assess the sensitivity of landscapes to developments and land use change. These are not regulatory mechanisms, but are intended to inform development plans, individual planning proposals, and other policies relating to land use change. These take landscape character into account. There are several types of landscape designations in Scotland with different regulations regarding energy developments. 

Policy 11d) of NPF4 states that energy development proposals that impact on international or national designations, such as National Nature Reserves, Sites of Special Scientific Interest (SSSI), Biosphere Reserves, Ramsar Sites, World Heritage Sites, and European Sites, will be assessed under NPF4 Policy 4, which seeks to protect, enhance, and restore natural assets. 

It is worth noting that some designated landscapes have presumptions against wind farms in the area, though are potentially more permissible of other renewable energy developments. 

Local landscape areas (LLAs) are designated by local authorities. Each local authority can also develop specific policies and objectives for their LLAs, some of which may relate to energy developments. Policy 4d) of NPF4 states that development on sites designated as local nature conservation sites or landscape areas within the LDP will only be supported where the development will not have significant adverse effects on the quality of the site or where economic, environmental, or social benefits clearly outweigh these adverse effects. 

Each local authority area can also develop their own specific policies for LLAs, which can typically be found in the Local Development Plan or in its supplementary guidance. More information on local landscape areas can be found here

National Parks and National Scenic Areas

There is a long-standing presumption against wind farms in National Parks and National Scenic Areas, which is reiterated in NPF4 (policy 11b). Other renewable energy developments are potentially permitted in National Parks and National Scenic Areas, unless that area falls under another land designation with a presumption against development. However, for the development to be supported the objectives of designation and the overall integrity of the areas will not be compromised, or, any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social, environmental or economic benefits of national importance (NPF4 Policy 4c).

For areas nominated to be Scotland’s next National Park, the Scottish Government has given a reassurance that preexisting wind farms in or adjacent to the area would not be a barrier to it being selected, and that they will review planning guidance on windfarms for new National Parks. This means that policy in new National Parks could be different to that covering the existing ones. It is therefore not yet clear if there will be a presumption against further development in areas chosen as new national parks. 

Wild Land Areas were designated by NatureScot (then Scottish Natural Heritage) in 2014 and can be seen on this map. NPF4, Policy 4 (Natural Places) states that renewable energy development proposals in areas defined as Wild Land Areas by NatureScot will be supported. The development proposal must be accompanied by a wild land impact assessment which sets out how design, siting, or other mitigation measures have been and will be used to minimise significant impacts on the qualities of the wild land, as well as any management and monitoring arrangements where appropriate. 

Wild land was previously more strongly recognised as a finite national resource and had greater protection from development in the previous Scottish Planning Policy, which ran from 2014 to 2019. These protections for wild land were typically upheld in development proposals. The John Muir Trust’s casework on planning applications in wild places is a good resource for more information on developments in Wild Land Areas. 

European sites (Special Areas of Conservation or Special Protection Areas, previously known as Natura sites): 

Developments likely to have a significant impact on these sites will be subject to an appropriate assessment on the implications for the conservation objectives of the site. This applies to existing and proposed European sites. Policy 4 says that development which will have an unacceptable impact on the natural environment will not be supported. The EU wind energy developments and Natura 2000 guidance still apply in Scotland. Ramsar sites are also European sites and/or SSSIs

More policies and guidance notes on energy developments and visual amenities can be found here

How will the cumulative impacts of energy developments be addressed?

Cumulative effects may occur where several wind farms and their associated infrastructure are present within a relatively small area, or where energy infrastructure is present alongside other anthropogenic activities (eg. commercial forestry, industrial development). It is the combined effect of all development in an area taken together. For example, one wind farm may not displace a bird habitat to a great extent, but several farms and an area of non-native forestry together could cause significant disturbance and result in a loss of that bird population from the area. This influences the planning decisions for all wind farms in that area. Habitat fragmentation may also need to be considered during the assessment of cumulative effects as this can have an adverse impact on population structure and dynamics among a wide range of species. Addressing the cumulative impacts of proposals is complex, especially when several developments are being proposed at the same time

NPF4 states that:

“adverse impacts, including cumulative impacts, of development proposals on the natural environment will be minimised through careful planning and design, taking into account the need to reverse biodiversity loss”.

Policy 3d) NPF4

NPF4 Policy 11e), on energy, states that renewable development proposals must address the cumulative impacts of that project. Policy 11 e) lists all the considerations that the project design should avoid, including impacts on communities, visual impacts, public access etc. So it seems that, in NPF4, ‘cumulative impacts’ could be interpreted as both the impacts of lots of different developments and the combination of lots of different types of impacts arising from one development or a few developments. Schedule 4(5) of The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017 states the need for cumulative impacts to be considered at a project level.

Specifically regarding wind farm developments, under NatureScot guidance the cumulative impact is a combination of:

  • the distance between individual wind farms (or turbines),
  • the distance over which they are visible,
  • the overall character of the landscape and its sensitivity to wind farms,
  • the siting and design of the wind farms themselves, and
  • the way in which the landscape is experienced.

More detail on the process of assessing cumulative landscape and visual impacts of wind farms can be found in the NatureScot guidance. NatureScot have also produced guidance on assessing the cumulative impact of onshore wind farms on birds.

Developers of a wind farm must consider the potential for cumulative effects to arise from the interaction of the Proposed Development with other wind energy developments within up to 35 km of the site that are either operational, consented and/or under construction, or are in planning either with an application that has not yet been determined or subject to an appeal.

Recognition of the need to expand renewable energy developments has not been met by a strategic approach to doing so, with permission for developments being granted on a case by case and ‘first come, first served’ basis. APRS believe that a more strategic approach to planning energy developments could help minimise impacts, including cumulative impacts. Strategic planning not only helps to identify the most appropriate locations and scales for expansion in function of wind energy capacity, grid access etc. but also helps to avoid and reduce the impacts on the natural environment at a very early stage in the planning process.

An interactive map of all renewable energy developments in Scotland can be seen here.

Is an Environmental Impact Assessment needed?

Energy consents differ slightly from other forms of developments in terms of Environmental Impact Assessment (EIA) requirements. While EIA conditions and requirements are set out in the Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017 for most types of developments, EIA requirements for energy developments fall under the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017

An EIA is required for a nuclear generating station, a thermal generating station with a heat output of 300 megawatts or more, or the construction of overhead power lines with a voltage of 220 kilovolts or more and a length of more than 15 kilometers. Changes to these developments where the change would mean the development meets these thresholds also requires an EIA. If the development is likely to have significant effects on the environment by virtue of factors such as its nature, size or location, an EIA is required for a generating station, an electric line installed above ground with a voltage of 132 kilovolts or more, in a sensitive area. Any changes to these developments which could result in a significant adverse effects to the environment also require an EIA. 

Under these regulations, a sensitive area is defined as 

  • A site of special scientific interest
  • Land under a nature conservation order
  • A European Site under the Conservation of Habitats and Species Regulations 2017
  • A World Heritage Site
  • A scheduled monument under the Ancient Monuments and Archaeological Areas Act 1979 
  • A National Scenic Area
  • National Parks
  • Marine Protected Areas

The characteristics of the development which must be considered in determining whether an EIA is needed are:

  • the size and design of the development;
  • cumulation with other existing development and/or approved development;
  • the use of natural resources, in particular land, soil, water and biodiversity;
  • the production of waste;
  • pollution and nuisances;
  • the risk of major accidents and/or disasters which are relevant to the project concerned, including those caused by climate change, in accordance with scientific knowledge;
  • the risks to human health (for example due to water contamination or air pollution).

With regards to the location of the development, the environmental sensitivity of areas must have regard to:

  • the existing and approved land use;
  • the relative abundance, availability, quality and regenerative capacity of natural resources (including soil, land, water and biodiversity) in the area and its underground;
  • the absorption capacity of the natural environment, paying particular attention to the following areas—
    • wetlands, riparian areas, river mouths;
    • coastal zones and the marine environment;
    • mountain and forest areas;
    • nature reserves and parks;
    • European sites and other areas classified or protected under national legislation;
    • areas in which there has already been a failure to meet the environmental quality standards, and relevant to the project, or in which it is considered that there is such a failure;
    • densely populated areas;
    • landscapes and sites of historical, cultural or archaeological significance.

If an EIA is required for a development, then policy 3b) of NPF4 applies. This requires the developers to demonstrate how the proposal will conserve, restore, or enhance biodiversity so they are in a demonstrably better state than without intervention. If an EIA is not required, then policies 3c) and 3d) apply. These require proposals to conserve, restore, and enhance biodiversity in accordance with local and national guidance and minimise potential adverse impacts. 

Will developments be permitted on peatlands or carbon-rich soils?

Carbon-rich soils are peat soils and peaty soils.  Peat soils in Scotland are defined as soil with a surface peat layer with more than 60% organic matter and of at least 50cm thickness.  Peaty soils have a shallower peat layer (<50cm) at the surface.

Peatlands are becoming increasingly recognised as valuable habitats in reversing biodiversity loss and keeping carbon stores intact. Most Scottish peat bogs contain more than 5000 tonnes of carbon per hectare, and it is widely accepted that peatlands are the single most important terrestrial store of carbon globally. 

While Scottish planning policy recognises this importance, it permits energy developments on peatlands and carbon rich-soils, though certain criteria must be met. A key focus would be on ensuring that the development is in line with the mitigation hierarchy set out in NPF4, and that there is biodiversity enhancement in the form of peatland restoration. The mitigation hierarchy indicates the order in which the impacts of development should be considered and addressed. These are: 

  1. Avoid – by removing the impact at the outset 
  2. Minimise – by reducing the impact 
  3. Restore – by repairing damaged habitats 
  4. Offset – by compensating for the residual impact that remains, with preference to on-site over off-site measures

Policy 5 of NPF4 recognises the importance of these habitats and seeks to “protect carbon-rich soils, restore peatlands and minimise disturbance to soils from development”. However, 5 c) states that “development proposals on peatland, carbon-rich soils and priority peatland habitat will only be supported for… the generation of energy from renewable sources that optimise the contribution of the area to greenhouse gas emissions reductions targets”. So where a renewable energy development would reduce greenhouse gas emissions more than avoiding impacts on the peatland, the development will likely be supported, though this does not account for the biodiversity value of peatlands. This policy also states that, for essential infrastructure (which includes energy developments), developments will only be supported where “there is a specific locational need and no other suitable site”. So, taking these policies together, proposed developments on peatland or carbon-rich soils would have to outline why a development must be located on that site, and how it would optimise the contribution of that area to greenhouse gas emissions reduction targets. 5 d) states that 

“Where development on peatland, carbon-rich soils or priority peatland habitat is proposed, a detailed site specific assessment will be required to identify:

  1. the baseline depth, habitat condition, quality and stability of carbon rich soils;
  2. the likely effects of the development on peatland, including on soil disturbance; and
  3. the likely net effects of the development on climate emissions and loss of carbon.

This should include peat depth surveys (initial, detailed and additional information), Peat Landslide Hazard Risk Assessment (PLHRA), and detailed habitat surveys (NVC), including an assessment of condition. Further information on these requirements can be found in NatureScot guidance on peatland habitats in development management. This guidance also outlines priority peatland plant species and habitats that development proposals should consider and completely avoid. Montane bogs are blanket bogs that occur at altitudes above 600m, they are particularly sensitive to damage and are incredibly difficult to restore. Development proposals should completely avoid these habitats. Flagging the presence of these priority habitats or species in consultation responses / representations where possible may help to ensure their protection. 

Some developments on peatlands may raise issues of national interest and warrant an objection. At the scoping stage of the development, developers must fill out an assessment of the site, the template of which can be found in Annex 1 of the NatureScot guidance. This determines whether the development could have a significant impact on priority habitats or species in the area. Specialist advice may also be used here. If it is confirmed that the habitat is priority peatland which is actively forming peat with indicator species and features of near natural condition, and taking into account the impacts and the mitigation hierarchy, that there are likely to be adverse impacts on that habitat, then the development could raise issues of national interest. 

The Scottish Government has also developed a landslide hazards risk assessment for wind farms, though this was published in 2017 and is somewhat outdated. They also developed a carbon calculator to assess the carbon savings from wind farm developments on carbon-rich soils when a loss of carbon from the soil is taken into account. However, it must be noted that this does not account for biodiversity impacts or habitat loss. This blog by the John Muir Trust details energy developments on peatland which have been assessed under NPF4.

How can communities benefit from energy developments?

In their draft Energy Strategy and Just Transition Plan, the Scottish Government has stated that they are encouraging developers to offer community benefits and shared ownership opportunities as standard in all new energy projects. Policy 25 of NPF4 deals with community wealth building. This states that development proposals which contribute to local or regional community wealth building strategies and community ownership will be supported. 

Some energy developments can make financial contributions to the local community. This is often a set amount of money per unit of energy generated, which can be invested back in community amenities. This would likely be mentioned in the development proposal, or you can ask your planning authority whether any community benefits are part of the development. 

Further resources: 

Scottish Government guidance on community benefit from onshore wind

Scottish Government good practice principles for community benefit from offshore wind

Will I be consulted on energy development applications in my area?

When applying for consent for developments over 50MW, a developer must advertise it with a public notice in the Edinburgh Gazette, one or more national newspapers, and in one or more local newspapers unless the Scottish Ministers direct otherwise. In areas where Gaelic is predominantly spoken, it is good practice for developers to place all public notices in both English and Gaelic languages. 

The Energy Consents Unit website lists applications and decisions made. The website itself does not give a lot of information on the development, so you may need to do a web search the name of the proposed development to get more information. 

For developments below the 50MW threshold, you will need to search the planning portal of your local authority’s website. Many local authority websites allow you to perform an ‘advanced search’ where you can often search the type of development from a drop down list. Community Councils relevant to a development should be consulted before and after the application has been submitted, as detailed in Planning Advice Note 3/2010. You can also contact them if you have any thoughts on a proposed development.

There are some legal requirements as to who should be consulted in energy development applications. These include the planning authority, NatureScot, the Scottish Environmental Protection Agency (SEPA), and Historic Environment Scotland. At the pre-application stage, the developer is also expected to carry out, at a minimum, two public consultation events, held at least 14 days apart. These should be published in a local newspaper and on the developers website at least 7 days before the event. 

The Scottish Government recognise that effective engagement with the public can lead to better plans and improve the fairness of the planning system. They emphasise meaningful and early engagement with communities and for public views to be reflected in final plans. Everyone has the right to comment on any planning application, and planning authorities must ensure that the public are given an opportunity to comment on any application. However, due to a lack of resource amongst planning authorities and the complexity inherent in the planning system, it is often difficult for communities to get involved in planning processes. Planning Democracy’s guidance on responding to a planning application is a really helpful guide to aid you through the process of responding to development applications. 

Some energy developments fall under Permitted Development Rights, which are automatically granted planning permission through government legislation rather than an application to a local authority. However, these are usually small scale solar or solar on buildings or as a canopy over car parks. 

More information can be found on this page.

Can a proposed development that would harm trees/woodland be allowed?

Policy 11 of NPF4 (Energy) states that any proposed renewable energy project must address and mitigate any impact on trees, woods, and forests. Policy 6 (Forestry, Woodland and Trees) states that development proposals will not be supported where they result in

  • A loss of ancient woodland or trees or an adverse impact on their condition
  • Adverse impacts on native woodlands, hedgerows and individual trees of high biodiversity value
  • Fragmentation (splitting) of woodland habitats

Policy 6 also states that removal of woodland would only be supported where they achieve significant public benefit and is consistent with Scottish Government policy on woodland removal, which lists renewable energy development as a case where removal of trees and woodland is deemed acceptable. However, as the Scottish Government has stressed that NPF4 is to be read as a whole, Policy 3, which aims to protect biodiversity, reverse biodiversity loss, deliver positive effects from development and strengthen nature networks is also relevant here.

The general rule with woodland removal seems to be that disturbances should be mitigated, though woodland removal is allowed where it would achieve ‘significant and clearly defined additional public benefits’. This statement can be fairly subjective, however. The planning proposal should provide justification and evidence for the need for any woodland removal.

The Scottish Government’s policy on control of woodland removal implementation (2019) states that the removal of large areas of woodland will not be supported. This document also provides more detailed information on where woodland removal will/will not be supported.

The UK Forestry Standard is the Government’s reference standard for sustainable forest management in the UK and provides a basis for regulation and monitoring. The Scottish Government expects all forestry plans and operations in Scotland to comply with the standards.

A Tree Preservation Order (TPO) is a legal document issued by a local authority that protects a specific tree or group of trees from being damaged, apart from any exemptions mentioned in the TPO. Individuals can apply for these in the case that it is in the ‘interests of amenity’ to protect those trees or if they are of significant cultural or historical significance. More information can be found through this guide prepared by the Environmental Rights Centre for Scotland.

Some more resources on forestry and energy development can be found here.

Are battery storage developments allowed on green belts?

The number of battery storage sites across Scotland is set to increase dramatically as part of the move towards renewable energy. These batteries are needed to store excess energy from renewable sources such as wind and solar and manage the difference between supply and demand of renewable energy. They must be strategically sited in areas where they will provide a steady supply of energy to homes and businesses while avoiding adverse environmental and landscape impacts. 

With regard to greenbelts, Policy 8 of NPF4 seeks to ensure that development is directed to the right locations and the character, landscape, natural setting and identity of settlements is protected and enhanced. It is supportive of renewable energy on greenbelts, though some conditions apply:

  • reasons must be provided as to why it cannot be sited outwith the greenbelt, 
  • it must be compatible with the character of the surrounding landscape character, 
  • it must be designed to minimise visual impact, and 
  • there will be no significant long-term impact on the environmental quality of the greenbelt. 

Some battery storage proposals could potentially be accommodated in an appropriate site within a designated green belt but only where it meets the conditions set out in NPF4 Policy 8 a) ii).  NPF4 Policy 9 clearly steers such development to brownfield or derelict land to reduce the need for development on greenfield sites. Policy 9 b) says that proposals on greenfield sites will not be supported unless the site has been allocated for development or the proposal is explicitly supported by policies in the LDP. 

The Scottish Government published a Planning Advice Note on energy storage, though this was published in 2013 and some elements may be out of date. 

Are solar developments allowed on green belt?

Solar farms, and renewable energy developments in general, are permitted on green belt where appropriate, though some conditions (laid out in Policy 8 of NPF4) apply:

  • reasons must be provided as to why it cannot be sited outwith the greenbelt, 
  • it must be compatible with the character of the surrounding landscape character, 
  • it must be designed to minimise visual impact, and 
  • there will be no significant long-term impact on the environmental quality of the greenbelt.

The green belt designation should remain on the site of the development as it is understood that renewable developments are permitted on allocated green belt, and NPF4 seems to expect that solar farm developments are time limited. For some applications we have seen 40 years mentioned in terms of land leasing for solar.  Assuming any review of the relevant LDP retains the Green Belt boundary and planning policy stays the same, after the (say) 40 years the green belt designation would remain and the policy protection against most forms of developments should remain. NPF4 policy 11 on Energy part f) says that consents for [energy] development proposals may be time-limited. Areas identified for wind farms are, however, expected to be “suitable for use in perpetuity”. You could ask your local authority if they do approve such developments they do specify the time period and ensure proposals for site restoration (if required) and “measures to safeguard or guarantee the availability of finances to effectively implement those plans”. Again those are required to be demonstrated by NPF4 policy 11.

A proposed energy development may harm a historic environmental site. Is this allowed?

Policy 7 of NPF4 seeks to “protect and enhance historic environment assets and places, and to enable positive change as a catalyst for the regeneration of places”.  It lays out the protections given to historic assets and places in planning decisions. It does not explicitly allow for energy developments in historic environmental sites. Applications will be assessed on a case by case basis.

NPF4 policy 7 requires development proposals with a potentially significant impact on historic assets to assess the visual and physical impacts of the development on those assets. Similarly, Policy 11 (Energy), states that the proposal must set out how energy project design and mitigation must address the historic environment. Note that policy 7 varies depending on the type of designation (eg SAM, conservation areas, World Heritage Site, Historic Marine Areas, Historic Battlefields, nationally important Gardens and Designed Landscapes).

Historic Environment Scotland (HES) is the public body responsible for the care and promotion of Scotland’s natural environment. Their role in the planning system is to provide advice and insight on the potential impacts of development proposals on the historic environment. They are also a statutory consultee for planning applications that affect world heritage sites and important historic environment sites and structures. HES have developed advice and guidance on the conservation of historic assets. If you are concerned about the impact of an energy development on a historic environmental site, Historic Environment Scotland may provide further advice. 

A map of historic environmental sites can be found through this portal, by clicking ‘filter’ and choosing the designation you are interested in. 

Some more resources on energy development and historic environment can be found through the Department of Planning and Appeals library section on cultural environment. See also an APRS representation regarding a battery storage facility near Cochno which would impact access, green belt and an important set of Neolithic carved stones.

There is an energy development proposed on my local green belt – will that remove the green belt designation?

In many cases if an energy development was permitted on a site within a designated Green Belt, the designation could remain in place. There may be sites within a Green Belt such as disused quarries where developments such as battery storage units could be potentially sited with little visual intrusion.

Planning policy (NPF4) seems to allow for solar farms on green belt and there is also an expectation that these developments are time limited and eventually removable. These can last quite a long time – for some applications we have seen 40 years mentioned.  However, assuming any review of the relevant Local Development Plan retains the Green Belt boundary and planning policy stays the same, after the duration the green belt designation would remain and the policy protection against most types of development should remain.

NPF4 policy 11 (Energy) part f says that “consents for [energy] development proposals may be time-limited. Areas identified for wind farms are, however, expected to be suitable for use in perpetuity”

The only way to be sure an area remains (or becomes) designated as green belt is via the local development plan. You can input to the LDP review process via your local authority’s consultations and engagement – see guidance here.

How can the visual impacts of overhead transmission lines be reduced?

One of the main ways of reducing the visual impacts of energy transmission lines is by replacing overhead cables with underground cables. It is used in limited circumstances, such as nationally recognised landscapes, though there has been calls to increase this. There is a higher initial cost to undergrounding cables, which explains why it is not very common at the minute, though long term they are less prone to damage and require less maintenance. However, the UK Government have previously stated that overhead cables will remain the standard method of energy transmission at the moment. 

NPF4 states that, “in the case of proposals for grid infrastructure, consideration should be given to underground connections where possible”. This line is somewhat vague and does not place and requirements on energy developers, though if you believe a transmission line project could/should be undergrounded, you may be able to ask what consideration has been given to this during the consultation process. 

There is some ongoing work to increase underground energy transmission to reduce visual impacts of energy infrastructure. SSEN are investing over £15m in a project which will see the undergrounding of 90km of overhead lines in Areas of Outstanding Natural Beauty, National Parks, and National Scenic Areas in the north of Scotland and southern England to reduce visual impacts. You can nominate a scheme for this project in Scotland through this link

Ofgem are also providing a £500 million fund for UK energy transmission owners to mitigate the visual impacts of infrastructure in a project called VISTA (Visual Impact of Scottish Transmission Assets). This aims to assess the visual impact of existing electricity infrastructure and identify the most effective proposals to mitigate these impacts. Currently, this projet can only focus on National Parks and National Scenic Areas due to their legal statuses. More information on this, including the current proposed projects, can be found here. This paper by SSEN describes some of the challenges to undergrounding. 

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