Initial response to 4th Scottish National Planning Framework - update

The fourth Scottish National Planning Framework (NPF4) has been published by the Scottish Government, setting out a long-term development and infrastructure plan for Scotland. Read our initial reaction on the implications for wild places - and recent update.

December update

On Friday 16 December 2022, Turcan Connell, instructed by the John Muir Trust, wrote to the Scottish Government formally stating a serious concern about the consultation process following publication of the Revised Draft National Planning Framework 4 (NPF4). 

On Tuesday 21 December 2022, The Local Government, Housing and Planning Committee published its report on the revised draft NPF4. This report noted 'The Committee welcomes the significant improvements that have been made to the policies on renewables. The Committee also welcomes the Minister's commitment to continue exploring issues of concern to stakeholders. We will monitor the effectiveness of these policies and the extent to which an appropriate balance has been struck between protecting wild land and progressing the development of renewables.'

Our initial response to NPF4 in November

While we welcome the continued recognition of Wild Land Areas, and the high-level focus on reversing biodiversity loss and protecting and expanding woodland - we are concerned about the reference to the potential for development in Wild Land Areas where it ‘will support meeting renewable energy targets.’

The vague language around ‘renewable energy targets’ in relation to development on wild areas leaves planning policy dangerously exposed to manipulation.

We will analyse NPF4 in greater detail and consult with partners and experts over the coming weeks to explore the true implications on this framework for Scotland’s wild places.

The John Muir Trust fully supports the Scottish Government’s bold and ambitious climate targets, and we recognise that Net Zero by 2045 will require expanding our renewables sector.

But Scotland must act wisely.

It is a false choice to have to decide between protecting our most precious wild places or sacrificing them for renewable energy development.

This is for two reasons:

• Firstly, wild places offer a huge, long-term natural solution. If protected and restored - our wild places have the potential to draw down greenhouse gases from the atmosphere in perpetuity. They also contain some of the highest carbon content soils which by contrast if ripped up for industrial scale renewable energy developments, will release vast amounts of carbon into the atmosphere as well as damaging biodiversity.
• Secondly, alternatives to onshore wind for delivering renewable energy at scale are advancing. Offshore wind capacity is developing rapidly, with 27GW in the pipeline compared to current onshore wind installed capacity of 8.6GW. There is also opportunity for far more small-scale community-owned renewable energy enterprises, that would circulate sustainable income and energy back into rural areas (see the Trust’s recently published document: A Just Transition and Wild Places).

A developer-led process in a lax regulatory regime will mainly benefit the giant energy companies and private landowners who have a huge financial incentive to gain  from high energy prices and public subsidies.

It is a false choice to have to decide between protecting our most precious wild places or sacrificing them for renewable energy development.

The Trust will be seeking to challenge the language in the policy and its implementation to make sure that wild places have a voice at the table and don’t pay the ultimate sacrifice.

We need to be convinced that any development is absolutely necessary and that there is absolutely no alternative before destroying our finite wild place resources.

Getting to this point

• The draft fourth National Planning Framework (NPF4) was published for public consultation on 10 November 2021, seeking views and comments on a wide range of topics including national developments and national planning policies.
• The consultation closed on 31 March 2022, receiving over 760 responses from a broad range of stakeholders, including the John Muir Trust.
• The responses informed the Revised Draft National Planning Framework 4, which was laid in the Scottish Parliament on 8 November 2022.