Interpreting NPF4 - an emerging issue for onshore wind development

Whilst the Council’s chief planning officer recommended approval of the scheme, the planning committee rejected the revised plans for Wull Muir Wind Farm, a project which had previously been knocked back in 2020 and dismissed in an appeal to the Scottish government.

In a nutshell, NPF4 – which became part of the development plan for all local planning authorities across Scotland in February last year – puts climate change at the heart of planning policy for the first time. NPF4 now forms part of the statutory development plan across Scotland, along with the current local development plan (LDP), and means that decision makers are obliged to give significant weight to the global climate crisis when considering development proposals.

What does NPF4 set out?

In terms of onshore wind farms, the following two polices are arguably the most salient.

Policy 1 of NPF4 states that “when considering all development proposals significant weight will be given to the global climate and nature crises".

Policy 11 of NPF4 states that in considering the impacts of a renewable energy development, “significant weight will be placed on the contribution of the proposal to renewable energy generation targets and on greenhouse gas emissions reduction targets”.

However, importantly, policy 11(e) also states that project design should demonstrate how to address “significant landscape and visual impacts, recognising that such impacts are to be expected for some forms of renewable energy. Where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered to be acceptable”.

So, how should NPF4 be applied?

What became apparent during the Scottish Borders Council Planning Committee meeting was the varying interpretations of how to apply NPF4.

Whilst NPF4 strengthens support for all forms of renewables development, including wind farms, there is nothing in NPF4 that of itself turns a non-acceptable wind farm site into an acceptable one. Scottish Ministers still stress, in post NPF4 decision letters, that the key test is the right development in the right place. This is a crucial piece of the puzzle that should lie at the heart of this decision making framework.

Heriot Community Council, who presented at the meeting, remarked that the Council’s planning officer, who had recommended the project’s approval, was treating NPF4 as a set of rules.

However, councillors were reminded that NPF4 is instead a framework with a set of criteria which are not prescribed and therefore requires professional judgement and evaluation on a case by case basis.

Councillor Viv Thomson said that NPF4 isn’t an “at all cost” policy and, in the case of Wull Muir, there wasn’t sufficient mitigation measures to ensure the right balance was struck between visual impact and the environment.

Councillor Marshall Douglas also reiterated the point that NPF4 is a framework that is not prescriptive – he said it should guide their decision making, but ultimately it comes down to the members to decide on the outcome. He said it needs to be the right scheme in the right place.

Councillor Neil Richards questioned the point of democracy which he felt was being jeopardised by those who voted in favour of the scheme based on their understanding of NPF4. He asked, “Shall we all just go home? This suggests that there is no democratic involvement here”.

We must also consider the backdrop of onshore wind farms today. According to data published by the Scottish government, as of the end of March 2024, there is 15.4 GW of operational capacity for renewable electricity generation in Scotland.

There are also 790 potential renewable energy projects, with a total estimated capacity of 46.8 GW, in the planning and construction pipeline.

Compare this with OFGEM’s prediction that by 2050 Scotland will need 9.4 GW in the Winter and 7 GW in the Summer.

From the data we can see that there is already a huge oversupply of wind powered energy in Scotland. So, perhaps this should be as much a factor in deciding whether wind farms are permitted or not?

NPF4 itself states that developments should be in the right place at the right time, and not at any costs.

In spite of the strengthened need for onshore wind projects under NPF4, it is not a trump card. Care is still needed in site selection and design mitigation, and the weight that NPF4 places on the global climate crisis should not automatically or always surpass all other factors.