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15 Sep 2020

GreenPower Responds to NatureScot’s Consultation on Landscape

In response to the NatureScot consultation on Landscape Sensitivity Assessment, July 2020, GreenPower would offer the following comments:

With a national state of emergency on the climate crisis declared by the Scottish Government, it is essential that national policy and government agencies are aligned to support that leadership and the delivery of stretching targets. ‘Radical planning policy’ [change] in the words of Scotland’s First Minister, is expected over the next 12 months and government is advised by the UK Climate Change Committee to plan for at least a trebling of onshore wind capacity over the next 10-15 years.

Self-evidently, any proposed change to landscape policy and any associated guidance that may have consequences for the planning process, targets and the climate emergency ought to take significant account of these imperatives and future directions in the national interest.

While some aspects of the consultation draft may be useful in relation to some forms of development the document overall comes across as one dimensional and negative in its approach to change in the landscape and we have a number of concerns around its implications for the climate emergency and the role of wind energy development to meet targets.

The one reference to the climate emergency made in the document infers that climate emergency policy, (which requires the deployment of modern, larger, more efficient wind turbines on a subsidy-free basis), is something that these studies need to respond to. (“The purpose or use of the landscape sensitivity study can vary. It can be required in response to development pressures (which can themselves be driven by policy or other considerations such as the climate emergency”).

The variable purposes intended by the above statement are not at all clear, however it does appear that the guidance considers development pressures from the climate emergency policy as a threat, particularly when read alongside other parts of the document which take a very narrow and negative protectionist approach to landscape change, and the backing of existing landscape capacity studies which are out of date and not fit for purpose.

Given the strategic threat to all landscapes and nature from climate change, we would recommend that NatureScot takes a less negative approach to prospective change driven by renewable energy development, so that any effect of sensitivity studies, or similar, provide a far more flexible and pragmatic contribution to the planning system. This is what the renewable industry needs in order to deliver on government targets, with the benefit of overwhelming public support for onshore wind, and so how these proposals fit into the wider public policy context and the decision making process will be important.

No-one thinks there should be wind farms everywhere, but the NatureScot proposal points to studies which may be used to narrowly determine landscape ‘acceptability’ of specific developments over all other considerations. Whether intended or not, this could also result in more unjustified subjective conflict in the planning system if used for spatial mapping to determine suitability and acceptability of development. Creating more heat than light in this way in the development management process would be a step in the wrong direction.

To attempt to use typology-based studies as the basis for spatial planning may appear to some decision-makers as being more ‘robust’ and helpful to ‘guide and enable’ development. However, the experience from Wales tells us that such an approach presents a significant risk of falling well short of its intentions and will likely create the opposite effect. The experience from the last 8 years or so since the adoption of landscape capacity studies and their incorporation into supplementary guidance and Local Development Plans is also instructive, where these appear to undermine SPP by creating quasi-Group 1 ‘no-go’ areas for onshore wind development and are often presented as a primary rationale for objection and refusal of consent, even in SPP Group 3 areas which favour wind development.

The document is also contradictory in several respects, for example it appears to turn away from out-of-date and highly subjective landscape ‘capacity’ studies which is welcome, but then it goes on to back the ongoing application and use of them. “Publication of this guidance does not mean that existing assessments are invalid. Many of these provide useful evidence and understanding to inform spatial planning, though some updating may be required as development patterns and technology change. The assessment criteria are likely to remain relevant.”

And despite stating that such studies are no substitute for project specific landscape assessment, it then states: “It may also be useful for those who will be using or consulting a sensitivity study, and/or using it to inform decisions” and that they can be used to “inform responses to individual or multiple planning applications” and “informing development plans”. This clearly recommends that they may also be used to create spatial plans for energy development led by subjective landscape concerns alone and to inform decision-making on specific projects. It may be arguable that this is beyond the scope of NatureScot’s remit.

We would advocate that it is time to rethink NatureScot’s apparent desire to see landscape studies inform spatial planning and to ‘guide and enable’ development from a landscape-led perspective. Rather, the approach should be less subjective and deterministic, and much more pragmatic to be just one of the factors in determining whether a development is acceptable or not. Any revision of the document should be much clearer that any such studies are simply background information to inform the LVIA and EIA processes over project development, which should always be considered on a case by case basis, and not contradict this in other parts of the guidance as illustrated above.

The mapping suggested in paragraph 3.3. appears to suggest a landscape-based spatial strategy and we would suggest this goes beyond the remit of NatureScot.

Paragraph 3.15 refers to design guidance for areas ‘identified as having some sort of potential to accommodate development’. This implies that areas may be identified as being unsuitable for development at a strategic level rather than on a site-by-site basis which may be inappropriate and contradicts the statement that Landscape and Visual Impact Assessments as just one part of the overall project assessment should be primary considerations. Further on in the document it refers to development being monitored which may have not ‘followed predicted locations’. This does offer some prospect that development may be possible outside areas identified by landscape studies, but it does reinforce the point that NatureScot anticipates sensitivity studies to make judgements on what is appropriate on a strategic level.

There appears to be a strong suggestion that designated and recognised landscapes can be used as a ‘sieve’. The implication here is that these areas would automatically be attributed a high sensitivity rating. The suggestion is made that ‘the presence of a designation in even part of an assessment unit would increase its value rating’ (p. 2.3.7). The example given is that the presence of Core Paths in an area would suggest a High Value rating. Does this approach allow for sufficient professional judgement and does it account for the variability in landscapes? It could also potentially overstate value and thus sensitivity where an area has been designated for non-landscape reasons.

NatureScot might also consider examining the premis of wider landscape policy and assessment which is to regard seeing a wind turbine in the environment as a negative, through varying degrees of ‘adverse’ impacts. This does not sit well with 79% public support for onshore wind. A re-examination of what constitutes susceptibility and value in GLVIA13 guidance in this context may also be worthy of consideration.

An example of this premis in the document is the phrase “The scope for landscapes to accommodate new land uses and development without losing their character and qualities varies from place to place.” In a climate emergency and with the broad public acceptance of wind turbines, is time up for such an assertion that all landscapes should only be suitable for development types that do not change their character and qualities, at all? We would suggest that NatureScot’s guidance on landscape sensitivity should not drift into use of language that implies any change as being inherently negative, which can in turn be used to pre-load judgements on acceptability.

It is not clear what is intended by this statement: “To ensure longevity of the assessment, anticipating future development scenarios should also be explored: this is particularly pertinent for wind turbines where turbine heights have been increasing rapidly over recent years.” If an intrinsically negative approach to onshore wind and landscape effects is maintained, and sensitivity studies are used to determine acceptability then any such study would risk pre-loading landscape considerations into the decision making process above all else.

In summary we would suggest a strong case for some serious re-alignment, and even perhaps a shake up to the starting position that wind turbines reflected onto the human retina be measured in degrees of ‘badness’. Project specific landscape and visual impact assessments should be considered on a case by case basis, and there is plenty of landscape character information upon which to base them to deliver responsible development. If we are to have subjective landscape ‘sensitivity studies’ they should be non-deterministic at all levels of planning decision-making, and should not be translated to spatial plans for what is considered acceptable or not.