
25 Mar 2026
The Scottish Government is running a consultation on whether to increase the current threshold for Scottish Ministers to assess windfarm applications from 50 megawatts (MW) to 100 or 150 MW.
This is a very short consultation with only six questions to be completed. Please see our sample responses below, or submit your own response, by the end of this week.
The current situation is that applications for all schemes of 50MW or more are determined by the Energy Consents Unit (ECU) in Glasgow. This means that democratically elected local councils are shut out of decision making for major schemes that will have a huge impact on the local landscape. This is anti-democratic and significantly undermines the ability of local residents to have a say on major developments in their area.
If the threshold were to be raised, even slightly, this would allow local authorities more opportunity to object to a major windfarm in an area where there are already multiple windfarms, or on a site which is particularly sensitive due to its important archaeology, history, culture or wildlife.
Between 2021 and 2024, approvals for windfarm applications have averaged 81 per cent.
Our suggested responses to the consultation are as follows:
Question 1
Should there be a single threshold applicable to all technologies?
Answer: Yes
Question 2
What threshold should apply for applications for electricity generation to be determined by planning authorities?
Answer: 150MW
Question 3
Any change to the threshold would apply only to new applications. Do you have any comments on transitional arrangements?
Answer: During the transition period, all applications for onshore electricity generation and storage should be assessed by the local planning authority. Local councillors are in a position to understand the full impact of any new development on the local area, including the cumulative effect of multiple developments.
Question 4
Do you have any other comments to add?
Answer: We recommend the threshold should be raised significantly to allow local authorities to properly exercise their duty to represent local communities. A threshold of 500MW would be far more appropriate.
Question 5
Do you have any comments on the partial and draft impact assessments undertaken?
Answer: The Energy Consents Unit has reduced the level of engagement with local communities and is allotted 50% of the fee paid for applications made under the Electricity Act 1989. It would be better if all of the fees were paid to local authorities, which are required to conduct a significant amount of work evaluating applications.
The whole of National Planning Framework 4 (NPF4) should be reviewed, as it has resulted in the vast majority of onshore projects receiving consent, often against the wishes of local communities. There must be a proper cumulative impact assessment on the effect of further development on regions with a high number of windfarms already built. NPF4 states that ‘localised’ effects are acceptable, which is totally against the Scottish government’s stated ethos of engaging with local communities.
Question 6
Do you have any suggestions for additional sources of information on the potential impacts of the proposals that could help inform our final assessments?
Answer: NPF4 discounts Landscape Capacity Studies across Scotland, and states that their conclusions are not valid. Landscape Capacity Studies should be reinstated as part of the planning system, to enable proper evaluation of all onshore electricity generation schemes.
There is already oversupply of power in Scotland relative to electricity demand. According to both Scottish Renewables and the Department for Energy Security and Net Zero, Scotland has an onshore wind capacity of 10GW, and a gross peak demand of 4GW.
In 2025, Scotland, according to Renewables UK, was operating 63% of the UKʼs onshore wind capacity. This is set to rise to 66% by 2030.
UK households are paying £6.6 billion to energy companies for not generating electricity because the national grid cannot handle the volume of renewable power produced by Scottish wind farms. These constraint payments have quadrupled in the past five years, reaching a record £1.7 billion in 2024/25.
Of the £6.6 billion spent over the past seven years, around £1.2 billion (approximately 70 per cent) was paid to wind farms in Scotland.
NESO estimates that curtailment costs could reach £8 billion by 2030.
For more details and to complete the consultation:
