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CAIRNGORMS NATIONAL PARK AUTHORITY 
Planning Paper 4, 8 September 2006 


CAIRNGORMS NATIONAL PARK AUTHORITY 


FOR DECISION 

Title: CNPA Response to Scottish Planning Policy SPP6: 
Renewable Energy Consultation Draft 
(available online at: www.scotland.gov.uk/Publications/2006/07/10150621/0) 

Prepared by: Gavin Miles, Planning Officer 


Purpose: 

This paper seeks the Board’s endorsement for the Park Authority’s response to 
the above consultation from the Scottish Executive Development Department. 


Recommendations: 

That the Board endorse and approve the following points with additions or 
amendments to be formally sent to the Scottish Executive: 

1. The CNPA seeks further clarification in the finalised SPP over how 
planning authorities should consider the direct and cumulative impacts on 
National Parks of wind farms outside the National Park Boundary and how 
the impacts on “wild land” qualities both inside and outside the National 
Park should be assessed. 

2. The CNPA recommends that rather than a requirement for a percentage 
projected reduction in CO2 emissions via renewable energy production on 
developments, a range of higher targets for reducing projected carbon 
emissions for different kinds of projects are set to be achieved through a 
range of sustainable design, construction and operation measures. 


Summary: 

The Scottish Executive is consulting on a draft Scottish Planning Policy (SPP) 
document on Renewable Energy. This will replace the existing National Planning 
Policy Guideline (NPPG) on Renewable Energy Developments of 2000. Much 
of the draft SPP considers the development of spatial policy for onshore 
windfarm developments, while other forms of renewable energy, including 
microrenewables are also supported. The proposed response to the Scottish 
Executive seeks clarification over the ways in which the impacts on the National 
Park of windfarm developments outside the park boundary should be considered 
by planning authorities, and recommends an alternative approach to reducing the 
projected CO2 emissions of new development to that proposed in the draft SPP. 



Background: 

1. Scottish Planning Policies (SPPs) provide statements of Scottish 
Executive policy on nationally important land use and other planning 
matters. The Scottish Executive is consulting on a draft Scottish Planning 
Policy (SPP) document on Renewable Energy (available at 
www.scotland.gov.uk/Publications/2006/07/10150621/0). This will replace 
the existing National Planning Policy Guideline 6 (NPPG 6) on Renewable 
Energy Developments of that was last revised in 2000. Comments are 
requested by 6 October 2006. 

2. This SPP supports the Scottish Ministers’ target for generating 40% (now 
expressed as 6GW) of Scotland’s electricity from renewable sources by 
2020. In fact, this target may be exceeded as Scotland already had 
3.7GW of renewable energy consented in June this year, and the SPP 
makes clear that Ministers do not see the 6GW target as a cap and that 
planning authorities should consider it a minimum figure. 

3. A key theme of the draft SPP is that renewable energy developments can 
have environmental, social and economic benefits on a local or national 
scale and that these should be material considerations in planning 
decisions. It also highlights the importance of involving local communities 
in planning for renewable energy and outlines potential for communities to 
invest in renewable energy developments. 

4. Although the SPP considers the full range of potential renewable energy 
developments that are likely to be dealt with by the planning system, it 
acknowledges that it is onshore wind energy that is likely to make the 
greatest contribution to renewable energy generation. To support this, a 
large part of the SPP provides guidance for planning authorities on 
locational considerations for wind farms, including reference to topics such 
as natural and cultural heritage (including designated sites such as 
National Parks), tourism and recreation, aviation and defence, 
communities, cumulative impacts, wind resource and electricity grid 
capacity. 

5. Although the draft SPP is not prescriptive about where wind farms will be 
acceptable, it reinforces the view that internationally and nationally 
designated sites are less likely to be able to accommodate wind farms 
without unacceptable impacts. The draft SPP also states that while the 
potential impact of proposals on areas designated for their landscape 
value may be a material consideration in planning applications, planning 
authorities should not add additional zones of protection around such 
areas. 

6. The draft SPP proposes a standard separation distance of 1.5km between 
the edge of settlements and wind farm developments of over 20 MW that 
it would define as “large-scale wind farm developments”. 

7. There is support for a range of micro-renewable energy schemes that help 
reduce carbon emissions and provide reliable energy sources, and the 
draft SPP notes that the Scottish Executive is considering how 
microrenewables may be supported in the current review of the permitted 
development. The draft SPP seeks views on a proposal that planning 
authorities are required to ensure some types of development provide on-
site renewable energy equipment to reduce predicted CO2 emissions by 
a suggested minimum of 10%. 


Issues affecting the CNPA: 

8. The draft SPP provides a clear picture of the priority Scottish Ministers 
attach to the production of renewable energy and provides a reasonably 
clear context for the general approach to renewable energy development 
adopted by the CNPA to date. However, a number of the proposals within 
the SPP could be clarified, particularly where they related to the scale of 
development or the justification for consent. 

9. The most significant issue affecting the CNPA and its partner local 
authorities over the coming years will be in how to assess the direct and 
cumulative impacts on the National Park of wind farms outside the park 
boundary. The draft SPP states that broadly, any locations up to the 
boundary could be acceptable for renewable energy developments. In 
fact, the CNPA will be providing responses and potentially objecting to a 
large number of proposals visible from the National Park but both close to 
and far from its boundary. 

10. Allied to this concern over direct and cumulative impacts on the National 
Park designation, the draft SPP does not provide guidance on how to 
assess these impacts on “wild land” qualities, that may cross over the 
National Park boundary but that are important in creating the setting of the 
National Park within the central and eastern Highlands of Scotland. 

11. The support for micro-renewables in the draft SPP reflects the CNPA’s 
generally positive attitude to such schemes. However, the granting of 
permitted development status to such forms of development could lead to 
cumulative impacts that are outwith the control of either the CNPA or local 
authorities. The CNPA might make a valid case for not including 
developments that could have a significant local visual or noise impact, 
such as domestic wind turbines, within the permitted development types in 
the National Park. 

12. The support for community development of renewable energy schemes 
should be welcomed by the CNPA, although a revision of the interim 
planning policy on renewable energy to provide a more flexible definition 
of a community scheme may be required to encourage greater 
involvement. 

13. The proposal for a minimum 10% reduction in CO2 emissions from on-site 
renewable energy production for some kinds of development is possibly 
not the most effective method for reducing carbon contributions. Given 
that energy saving design, construction and efficiency measures can all 
contribute to the long term reduction in carbon emissions, a more 
appropriate approach may be to set a higher target to be reached through 
a wider range of measures that includes the design, construction and 
operation of the building, of which renewable energy generation may be a 
part. This is the approach that is likely to be advocated in the CNPA’s 
sustainable design guide and should allow for a more flexible approach to 
development. 


Gavin Miles 
Planning Officer (Local Plan/Policy)