Net Zero, Energy and Transport Committee

Meeting date: Tuesday, February 1, 2022

Official Report 697KB pdf

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National Planning Framework (Energy)

Agenda item 5 is our first evidence-taking session on the draft of the Government’s fourth national planning framework, or NPF4 for short. A number of committees are scrutinising different elements of the framework, and our focus is on how effectively it addresses energy policy, particularly in the context of the national commitment to achieve net zero by 2045.

I am pleased to welcome to the meeting Dr Niall Kerr, interdisciplinary research fellow, energy and climate policy, University of Edinburgh; Morag Watson, director of policy, Scottish Renewables; Elizabeth Leighton, secretariat, Climate Emergency Response Group; and Kirstanne Land, senior external relations manager, Scottish and Southern Electricity Networks Transmission. Thank you for taking the time to join us this morning. I also thank those who have made submissions in response to the Parliament’s call for views—they have all been noted.

I will start with a question for all the panel members. One of the main themes of NPF4 is the prioritisation of localisation across a number of policy areas. The committee is undertaking a major inquiry into the role of local government in meeting our net zero targets. How important will local authorities be in meeting those targets through, for example, transport, procurement, the circular economy and the decarbonisation of heat? What are the main challenges that they face in that respect?

I will bring in each panel member in the order in which I introduced them. Over to you, Niall Kerr.

Hello and thank you for the invitation to give evidence to the committee. With regard to the role of local government, the committee will be aware that local heat and energy efficiency strategies are being designed and piloted by local authorities, alongside the Scottish Government, and that local authorities have been given a key role in heat decarbonisation and energy efficiency planning in Scotland.

You will probably also be aware of the need for local government to have the necessary budget and expertise to achieve heat decarbonisation. It has a focus on and a key role in achieving heat decarbonisation in social housing, but there are other aspects that local authorities have little, if any, control over, not least the existing private housing stock, be it owner-occupied or rented. A significant contribution will have to be made at the national level through regulations and associated funding and financial incentives to ensure that the necessary changes are implemented.

That formal approach to local strategies has been taken in other countries. I am looking at heat decarbonisation in the Netherlands, where a similar approach has been taken to local heat planning. The formal requirement for municipalities to prepare strategies, for example, closely mirrors the situation in Scotland.

To sum up, local government has a critical role to play in local heat and energy efficiency strategies, but there are pretty obvious limitations to what authorities can do to achieve the full extent of the target on their own. It is therefore really important that national and local government work together. Indeed, a key feature of heat decarbonisation is the need for co-ordination between various parts of government and various public agencies.

Good morning. It is nice to speak to you all. We share the concerns that have been voiced extensively this morning about the capacity of local authorities and the budgets that are available to them. They have a key role to play in helping us to reach net zero, particularly in the areas that you outlined in your opening remarks, convener. However, according to research that we at Scottish Renewables have carried out specifically on the planning aspects of what local authorities do, the number of planning staff in local authorities in Scotland has dropped by 20 per cent since 2011. Our main anxiety about where we go from here is to do with how local authorities will cope with the huge upswing in activity that will be needed if we are to achieve our net zero goals.

Given that I am speaking on behalf of Scottish Renewables, I will stick to illustrating the issue with reference to renewable energy. We currently have 8.5GW of onshore wind in Scotland, but to keep us on track to meet net zero, we will need an additional 12GW by 2030. At the moment, we have around half a gigawatt of solar energy, but we will need 4GW to 8GW by 2030. In the offshore space, we will have to move from 1GW to 11GW, and then all of that will have to come onshore. All those projects need to go through the planning system, of which local authorities are a key part. Given that they are already overstretched, we have deep concerns about such a big upswing in work.

11:15  

We also have deep concerns for local authorities over the staff that they have, and the experience of those staff. Many experienced planning officers are retiring. The new people who come into the system are so pressured that they do not get out to do the professional development that they might have done in the past. There are shortages of ecologists, landscape architects and all sorts of specialist skills, which leaves local authorities struggling. They have a key role to play and are very important stakeholders and partners in all the work but, given the situation that they are in, we have deep concerns about their capacity to take on what we are going to have to do.

Hello. Thank you for inviting me along from the secretariat for the Climate Emergency Response Group, which is a leadership group of business and civic leaders, including my colleague Morag Watson, who have come together to urge the Scottish Government to have a more urgent and ambitious response to the climate emergency. We published a report in September that includes 12 proposals that could be taken forward immediately. One of those is on planning and one is on local government’s role in delivery. Those proposals are pertinent to our discussion today.

Local government is absolutely critical to achieving our net zero ambitions. It is estimated to have powers over about a third of emissions in its areas—for example, from transport, housing and planning. The pivot to delivery that the cabinet secretary spoke about in previous sessions is absolutely reliant on local authorities being equipped and having the capacity and resources to do their job.

One of our main recommendations is about making planning fit for a net zero future through gearing it up in 2022 so that the whole planning system—planners, councillors and reporters—has capacity and expertise that are fit for purpose. It is not that we do not know, in a sense, the answer. A very good piece of research that was done for Skills Development Scotland identifies that

“The evidence and data suggests that the sector may struggle in the future to attract and retain a sustainable workforce”

for the planning service. That would put at risk the achievement of national objectives, including

“achieving net zero emissions by 2045 ”.

The report includes an action plan to address that, but it was published in February 2021. What has happened to that action plan? What has been done? As you said earlier, convener, the clock is ticking. The issue is urgent and it needs to be addressed now. We need emergency measures to address the gap in capacity, as well as longer-term skills development over a four or five-year horizon to fill the gaps.

Good morning. I am here on behalf of SSEN Transmission, which is the company that owns, operates and develops the transmission network in the north of Scotland and the remote Scottish islands, with the aim of delivering a network for net zero. We are a regulated business. Our key role is to connect to the grid the renewable energy that is needed to support the emissions reductions targets of the UK and Scotland, and to take it to where it is needed across Great Britain.

Our network area in the north of Scotland, in particular, will play an outsized role in meeting the renewable energy targets of the UK and Scotland. According to our analysis, it will contribute up to 10 per cent of the UK’s net zero target. Through the current price control, RIIO-T2, we are planning to invest at least £2.8 billion between now and 2026, and potentially to increase that to more than £4 billion, in order to deliver our network for net zero in the north of Scotland. In doing so, we will look to double our workforce between now and 2026.

However, as other panel members have referenced, delivery timescales are incredibly challenging, and the levels of investment that are required to support net zero are going to be unprecedented. Our network has probably not seen such a level of investment since the 1950s. Significant investment will be needed in Scotland’s grid infrastructure between now and 2030 to deliver on the net zero targets at scale and pace, and planning will play a pivotal role in that.

I echo the comments of the witnesses who spoke before me. Successful delivery of NPF4’s net zero objectives will depend on a supportive planning process that is responsive to the levels of investment that will be required to achieve Scotland’s climate goals. Having adequate levels of planning resource will be vital to unlocking that.

The NPF4 document recognises that increases in planning fees are planned to help to address that issue. However, they will not support better quality and more timely decision making unless we also have further investment, resources and skills planning. As Morag Watson said, the number of planners is actually decreasing at the moment, and we are already feeling the impact of that in the consenting timescale for our current projects. Along with the increases in planning fees, it would be helpful to have that money ring fenced so that it stays in local authority planning teams. That could improve planning determination outcomes.

Thank you for those opening remarks. I want to pick up on two issues that were raised. The first is the concerns about planning capacity and expertise at the local authority level, which was mentioned by Morag Watson, Elizabeth Leighton and Kirstanne Land. How much of a bottleneck will that cause in approval of the various projects and the capacity that will be required to meet the targets? What needs to be done to resource local authorities better in order to help them to reach their net zero targets?

I have a separate question for Dr Kerr. I know that you have looked at the decarbonising of heat in other countries. The evidence that we have heard from local authorities indicates that they have concerns about reaching the heat in buildings target for 2030. Some of them have said that it might not be achievable at all. Do you share those concerns? If so, what practical policy measures need to be put in place to help local authorities to meet that 2030 target?

Our colleagues at the Royal Town Planning Institute are researching what the skills demand for the planning system will be in the future, and it is calling for a strategic skills and workforce development plan for Scotland. We fully support that call and are looking for that plan to come forward.

We heard from the cabinet secretary earlier this morning that we find ourselves in a constrained financial situation because of the pandemic and many other factors so, although it is desirable that local authorities find the funding for this, we understand that that is not as straightforward as we would want it to be.

There can be a lot of repetition in the planning system. In the area of renewables, timeframes and planning processes are so long that, by the time you have your onshore wind farm consented, the model of turbine that is in your consent is no longer on the market, because newer ones are available. You then have to go back through the planning system to get the proposal reconsented with the turbines that are now available. We see such churn going through the planning system. If we can streamline our processes more so that our planning system is predictable and can deliver consents rapidly, we will take a lot of strain off the planning system that is caused by people having to go back and revisit planning applications again and again.

We are working with colleagues in the Scottish Government on research into how we can reduce planning timescales. We need to start front loading what we are doing, with pre-application consultations. That will mean that everybody has a chance to comment on an application before it goes into the system, and any changes that are asked for can be made before the application stage. At the moment, people have to wait until the application is live before they comment. That means that the application has to go back to the drawing board to take in comments, which takes up a huge amount of capacity in the system. If we can unlock that and stop using capacity to go over the same ground again and again, that will make a sizeable difference to our planning system.

Thank you very much, Morag. That was very helpful. Elizabeth—I put to you the same question on planning.

I support what Morag said about the RTPI work that Scottish Renewables has been involved in with the Improvement Service and Skills Development Scotland. I mentioned the report on the planning workforce. That is more a medium-term to long-term answer, so we need to ask what we can do in the meantime.

We can learn from how resources were accessed during the Covid pandemic and how people were redeployed and brought in from other professions to support the Covid response. Such things have to be considered for the planning workforce, which is declining, as several people have mentioned.

There are other ways to do some of the work and preparation to make planning decisions easier. For example, the local heat and energy efficiency strategies will be critical to guiding planning decisions, but many of them are still not in place. Local authorities have probably given evidence to the committee about how difficult it will be to complete that task by the expected date. More up-front support needs to be given to local authorities now—without waiting for the public energy agency to be put in place—to make sure that the strategies are in place as soon as possible, because they will guide many decisions for local authorities that do not have a lot of expertise on energy master planning. The same would apply for heat networks; heat partnerships could assist in building expertise and sharing that resource across some local authorities.

There is also a need for guidance, including on how to do carbon assessments and how to assess whether a project will be resilient to the impacts of climate change. Such guidance could be brought into play relatively quickly by using guidance that is already being used by project managers in city region deals and growth deals. That, too, would be useful for planners. We should make use of what we have now rather than duplicate it or reinvent the wheel. This is about working regionally and working in partnerships to come up with immediate solutions, as well as being about resourcing longer-term workforce planning.

Thank you very much, Elizabeth. I put the same question to Kirstanne.

I do not have a huge amount to add to what has been said by fellow panel members.

On skills, a key bottleneck for us is caused by the differing levels of expertise in local authorities, which really hits home in respect of the biodiversity side of our developments. As a business, SSEN is committed to delivering a greener grid. We tend to focus on habitat restoration and on creating biodiversity growth as we invest in our network. Through that, we have committed to delivering a biodiversity net gain on all our new sites by 2025; we are targeting no net loss at the moment.

When we engage with local authorities on biodiversity, we find that availability of skills is very varied. There is also no guidance to give local authorities direction on what standards of biodiversity should be achieved. We therefore experience real inconsistency in approaches in terms of the expectations of local authorities for what should or should not be delivered, which differs from project to project.

In the NPF4 no agreed set of standards is outlined in the draft of policy 3, on the nature crisis. We think that that should change. There should be more direction in NPF4 to guide local authorities. We are already experiencing the impact on our projects. Inconsistency creates delays, as different people have different expectations about what should be delivered. Greater clarity in NPF4 would definitely help to clear the bottleneck.

Thank you. That was helpful. Dr Kerr, I asked you about heat in buildings, but feel free to respond to the question on planning as well, if that is also within your remit.

11:30  

I will focus on targets for heat in buildings. It is fair to say that the targets, particularly for 2030, are hugely ambitious. I recently did a little bit of work looking at heat decarbonisation policy, including looking at incentives and regulations as well as targets in European countries. The work showed that compared with that selection of countries, Scotland has hugely ambitious heat decarbonisation targets for 2030. Scotland is also starting from quite a low base in terms of the number of properties that currently use low-carbon heat.

We have for years had in place incentives, such as the renewable heat incentive and various schemes for heat networks. That has resulted in some uptake, but nowhere near what will be needed to achieve the 2030 target. The point is that the target is, undoubtedly, hugely ambitious and will be difficult to achieve.

I suppose that the more interesting question is whether a highly ambitious target for 2030 helps to promote effective implementation of the things that we ultimately need to do for 2045.

There is an undoubted moral imperative to implement heat decarbonisation and to decarbonise as quickly as we can in order to address climate change as expediently as we can. There is also a belief that there could be economic gains from moving quickly on heat decarbonisation: if Scotland moves particularly quickly, it can develop the industries and the companies of the future and achieve economic impacts and export potentials from the technologies.

The two key decarbonisation technologies that will play the biggest role in the 2020s are heat pumps, or some form of electrified heat, and heat networks. Low-carbon gas in the gas grid does not have much prospect of being introduced until possibly the 2030s, if it is to be introduced at all.

Heat pumps and heat networks are well-established technologies in other parts of the world. The economic impacts that could be secured in Scotland from their installation are not clear. Other countries are better versed in putting in heat networks, and companies in those countries are looking to install networks in Scotland.

As I have said, the targets are definitely hugely ambitious—some are the most ambitious in Europe, particularly for 2030—and there is a moral imperative to try to achieve them. However, the economic impacts that can be achieved from moving particularly quickly are up for debate. Technologies will be introduced in the 2020s, but they are perhaps not technologies that Scotland is leading in. However, there are supplementary technologies, including energy storage technologies and use of data to improve heating technologies and their performance, in which Scotland could possibly excel and produce valuable companies that would create an economic impact for the future.

Thank you, Dr Kerr. That was very interesting and helpful.

Good morning. I would like to address policy 19 in national planning framework 4. I will come first to Morag Watson and then to Kirstanne Land.

In its written submission, Scottish Renewables is clear that it does not think

“that this policy will ensure our places support continued expansion of low carbon and net-zero energy technologies”.

It goes as far as to say that

“there is a fundamental mismatch between The Scottish Government’s energy policy, particularly the draft OWPS [Offshore Wind Policy Statement], and NPF4.”

Could you, please, expand on that?

As we said in our submission, we have been absolutely clear and unequivocal that the draft text of national planning framework 4, as it stands, will not deliver the level of renewables deployment that we need to keep us on track to achieve net zero.

We also say about the NPF4 that the high-level principles are excellent. The key point is that addressing climate change and energy recovery should be the primary guiding principle in all decisions and plans. That is exactly what we need. Throughout, the NPF4 asserts the key role of more renewable energy in delivering net zero, which we absolutely agree with.

The problem comes when you start to look into the detailed text of the document. For example, climate change and nature recovery are primary guiding principles, but there is nothing in the document that provides guidance to a planning decision maker on how they should operationalise that and what it should mean in practice.

When you look at the text on renewable energy in particular, you find that it is often ambiguous and that a lot of it is contradictory and unclear. Policy 19 conflicts with what is in other policies—in particular, on scheduled ancient monuments, forestry and peatland—rather than trying to work with them. That is why we say that a fundamental rewrite of several sections of NPF4 is needed if we are to deliver on the ambitions. I reiterate that we are fully supportive of the ambitions of NPF4, but we are extremely doubtful that the text as written will deliver what ministers aspire to do.

I ask Kirstanne Land for her views on policy 19.

I would totally echo what Morag Watson said. There are some positive things in the draft NPF4. Morag talked about the overarching objectives. We certainly welcome the recognition of planning’s role in tackling the climate and environmental emergency, which is mentioned throughout the document. We are also supportive of the inclusion of renewable energy and transmission infrastructure as national developments, which will help to strengthen their role in tackling the climate emergency.

However, as Morag Watson has, we have concerns about the detail of specific policies in the document. Ultimately, that will be what determines how successful the NPF4 will be in delivering for our future low-carbon needs. Significant investment in renewable energy and grid infrastructure will be needed. The NPF4 needs to lay the groundwork for a clear, responsive, flexible and well-resourced consenting process, so that we get timely delivery of the infrastructure at the pace and scale that we need in order to meet net zero.

I echo Morag’s point that the NPF4 as drafted does not quite deliver that. The policies on wild land and green energy are quite contradictory—that is the feedback that we have had from our generation customers. That situation is unhelpful to them from a decision-making perspective, and it will create huge blocks to increased renewable energy development. As a stakeholder-led business that is involved in connecting renewable energy in the north of Scotland, we recognise the industry concerns regarding the misalignment between what is proposed, particularly in the onshore wind policy statement, and the NPF4, and what we want to advocate on behalf of the industry. The approach sends conflicting messages to industry and planners. Any uncertainty will create risk for net zero delivery.

From a transmission perspective, we are particularly concerned about the forestry and woodland policy, the current wording of which gives absolutely no flexibility at all and will, because of the extent of woodland coverage in our operational area, make it extremely difficult for us to deliver our critical grid investments. We think that rewording and redrafting will be required in several policies in the document in order to give much clearer direction in support of net zero targets. We want the document to be a bit clearer in support of net zero goals.

I have a short follow-up question. Kirstanne Land referred to the national development sites. Are they too restrictive? For example, Nigg port in the Cromarty Firth is not even mentioned.

We are supportive of the developments that are listed. Obviously, our key focus is on ensuring that the transmission network retains its status, because we think that it will be crucial in supporting the transition to net zero, as the backbone connecting to the renewables that will be needed. Other panel members might be better able to comment on other national developments. I do not have any more comments.

Thank you. I turn to other witnesses. I want to hear first from Dr Kerr, and then from Elizabeth Leighton, on policy 19. I am interested in the alignment between pursuing net zero and other requirements in relation to NatureScot and Historic Environment Scotland, for example. How can we ensure that NPF4 supports simultaneous assessment by—and, perhaps, early intervention by and work with—Historic Environment Scotland, as already happens in major transport schemes? Should that be applied to energy schemes?

Also on policy 19, how should small-scale renewables schemes be assessed and viewed in designated areas? Should support be given to community-owned projects? How does policy 19 help with that? What improvements are needed to help small-scale renewable projects?

Feel free to comment on anything that you have heard.

I have been focusing on policy 11 in relation to heating and cooling. I have prepared for that; I have not much to say on policy 19. I have various things to say on co-ordination in relation to heat decarbonisation, but I can save that for later.

Okay. I am happy to pass on my questions to others, but I am interested in the principle of co-ordination with other areas. Do you have any overarching views on that? Other witnesses can pick up the specifics.

I can mention a few things in relation to focusing on heat decarbonisation. Obviously, co-ordination is an extremely important part of that, but the draft NPF4 overlooks that at the moment. There is next to no reference to the role of electricity networks in heat decarbonisation, which Kirstanne Land might also want to speak about. The section on heating describes how heat networks will be implemented and how new developments need to consider their proximity to a heat network.

However, if the targets for 2030 are to be achieved, that will involve generating a huge amount of electrified heat—probably predominantly through heat pumps. If hundreds of thousands of heat pumps are to be installed, an electricity network that is able to accommodate that will be required. There is an expectation that there will probably have to be some degree of network reinforcement.

The draft NPF4 talks a lot about heat networks, but it does not make reference to the importance of electricity networks being able to provide electrified heat. As I said, if the targets are to be achieved, hundreds of thousands of properties will need to use electrified heat.

The other aspect of co-ordination that is possibly missing is the new build heat standard for new developments—domestic and non-domestic properties—to use low-carbon heat by 2024. As far as I can recall, that is not currently mentioned in the draft NPF4. However, that is the sort of underpinning policy that is needed if low-carbon heat networks are to be connected to new developments so that they use electrified heat. That relates to the point about co-ordination of electricity networks.

If new developments are to use low-carbon heat from 2024, an electricity network that can accommodate heat pumps—or, at least, the potential for their use—in individual buildings might be needed. There might need to be heat pumps running on a heat network for new developments.

From my point of view, the planning framework is all about co-ordination and connecting different areas of Government, but that is not really addressed in the draft NPF4. The key co-ordinating points that are missing from the planning framework relate to the role of electrified heat and connecting electricity networks to new developments.

Perhaps Elizabeth Leighton could comment on the point about co-ordination, if she can. If we wait for everything to be aligned and co-ordinated, we might not get started on what we need to do. Your general view on that would be helpful, as well as your view on how we can support small-scale developments. Does NPF4 encourage that? If not, what needs to be done to help improve that?

11:45  

I agree completely that we cannot wait for everything to be perfect to get on with it.

Historic environment designated areas are a bit of an odd man out in the national planning framework, as the policy does not seem to give a nod to the change that has been made of giving significant weight to the climate emergency in planning decisions. The thresholds that are put in place for historic assets and places seem unnecessarily restrictive. The policy says that there should be no adverse effects rather than no unacceptable impacts. That is the language that is used in some other sections of the NPF, which set policies in the wider public interest of addressing the climate emergency. The policy on historic assets and places also does not seem to chime with the heat in buildings strategy, which says that a review of permitted development rights is under way and that work is being done on developing approaches for historic buildings and places to transition.

I would have liked the policy to have indicated much more of a shift in how we will respect the culture and integrity of our historic places but, at the same time, acknowledge that they need to, and can, adapt for climate impacts as well as reduce their emissions. I think that Historic Environment Scotland would support that. I would like that to change and clarity to be provided on it so that planning for zero-emissions systems, particularly microrenewables, in conservation areas becomes much easier. It should be more of a given and there should be more of a presumption in favour of it instead of all the hurdles that people have to face now, which seem rather out of date.

That answers your question on co-ordination. On community projects, I am not aware of much mention being made of community assets, but I imagine that it would be important to provide clarity on making it easier for community groups to apply for planning permission and for there to be more up-front support and assistance so that they can get through the planning process more quickly and easily.

Clarity is not just about the language in the NPF4—the actual words, such as “must” versus “should” and “will” versus “may”. We would like the language to be stronger, but clarity is also about being aware of co-ordinating with targets and other Government strategies, which can be enabling to planners and give them confidence in their decisions in favour of net zero. For example, on policy 19, if the Government had a policy for solar energy like the one on which it is consulting for onshore wind, that would strengthen the case for planners to make decisions in favour of it and acknowledge the significant weight of the climate emergency.

Historic Environment Scotland has founded a global heritage network on climate change, so perhaps it is more willing to address it than people might perceive.

I will direct two questions to Dr Kerr but, if anyone else wants to come in after he has answered, they should just indicate that.

Dr Kerr talked about heat networks and policy 11. That policy appears to prioritise heat networks—or what people might know as domestic heating—over other technologies. There is a presumption against domestic biomass where heat networks are available. Does that strike the right balance between heating technologies and site-specific solutions? Does it sufficiently recognise other solutions for heating that might be more financially viable or, indeed, practical?

The draft NPF refers to heat networks unduly. However, my understanding of heat policy is that other Scottish documents do not have such an emphasis on heat networks but refer to multiple different options. The problem with the draft NPF is that it mainly refers to heat networks.

However, as I have mentioned, there are policies such as the new build heat standard, which, from 2024, will require consented new buildings to have low-carbon heat. That could take a variety of forms; indeed, plans for heat network zones are referred to in the planning framework, with the presumption that, if you are in such a zone, you will use that network. However, the initial policy to think about is the new build heat standard and the fact that, from 2024, new buildings that have been given consent should use some form of low-carbon heat.

There might be a couple of things to say about competition between biomass systems and heat networks. The advice from the Climate Change Committee and, indeed, various organisations is that heat networks are more efficient and have better up-front and operational costs per household in heat-dense areas such as cities and large towns, so they are much more likely to be found there. Other countries have heat networks in all sorts of environments—for example, there are heat networks in many small towns in Denmark—but in this country they are being considered in relation to heat-dense areas such as cities.

The Climate Change Committee’s advice is that biomass systems should not be implemented in urban environments, partly because of the local pollutants that are emitted from biomass boilers. According to the Climate Change Committee, such boilers should be reserved for rural areas where heat pumps are not considered appropriate. There is also the potential to use biomass systems to run heat networks, as is happening in Denmark and Sweden, but there are carbon and pollutant capture considerations in that respect.

The main point is that the draft document puts a seemingly undue emphasis on heat networks as a low-carbon heat option when there are different options that could be considered. For example, reference has been made to electrified heat and biomass heating systems. As I have said, the new build heat standard gives an opportunity for many different low-carbon heat options to be considered, but at the moment there seems to be an undue emphasis on heat networks.

I want to make a final point about the new build heat standard that might seem like a divergence from the discussion but which it is important to remember. As far as I understand it, new buildings that receive consent from 2024 will have to use low-carbon heat, but that potentially allows a building to receive consent prior to 2024 and then to be built after 2024. There are examples that have been highlighted to the UK Government of house builders in 2018 building about half of their developments to 2013 standards. If that happens with the new build heat standard in Scotland—that is, if new buildings are developed to old standards five years after the regulations come in—that will have pretty serious implications for achieving the 2030 zero-carbon homes standard. In short, we have to think about the implications of a policy that is introduced in 2024 but which only applies to buildings consented after that point. It might be that new developments will not be fully low-carbon for seven years after 2024, and the implications for the very ambitious 2030 target need to be considered.

I cannot see whether anyone else wants to respond, so I will pose another question.

Dr Kerr referred earlier to the expectation that industrial developments with waste or surplus heat will be co-located with areas of demand. As we know, a significant proportion of demand will be for domestic heat. How do we strike a balance between using sources of low-carbon heat and building houses where people actually want to live?

Thinking about your last answer, I wonder whether that issue has been addressed anywhere else. What I am hearing from you—and, indeed, what we have seen in the submission from Scottish Renewables—is a feeling that this framework has been drafted somewhat in isolation. Is there anything else that we need to be aware of in this particular space?

I will answer that question and anyone else can come in after. On the point about co-locating waste heat sources, waste heat is regularly identified as one of the lowest-cost options if not the lowest-cost option for supplying heat to heat networks here and in various parts of the world, but it is not properly taken advantage of in Scottish or UK heat networks.

One of the paragraphs in the planning framework refers to co-locating potential future waste heat sources near to heat demand to ensure that waste heat sources can be used to run heat networks and supply low-carbon heat to properties. There are a couple of things to consider there in relation to future developments. The largest waste heat source in Scotland is waste water treatment plants, but for various reasons you may not want to site new waste water treatment plants near to heat demand.

The other thing to think about is the production of hydrogen, which I have been reading about recently and may result in large amounts of waste heat. That could perhaps be sited near to sources of heat demand. The production of hydrogen, perhaps for use in industry, produces a lot of waste heat and could therefore help to feed a nearby heat network. That would provide a low-cost heat source for a heat network and possibly provide a source of revenue for the hydrogen production. There are various regional considerations in relation to where hydrogen production may take place, and there is the potential for waste heat that could help provide synergies for low-carbon heat networks.

I will come in on the previous point about heating and cooling and the technologies that were addressed. I draw your attention to the fact that the Government plans to introduce regulations not only for new builds but for existing properties to transition to zero-emissions heat. That is yet another reason why it is important that individual technologies and the full range of technologies are not neglected in policy 11 on heating and cooling, policy 19 on green energy, or policy 28 on historic assets and places. That is another example of the alignment that needs to be made with strategy.

I will throw some light on how heat is being treated in planning and what we are looking for. We are looking to other Government documents—[Inaudible.]—to do that strategic thinking about what technologies should be used where for decarbonisation. We are looking for the NPF4 to provide an enabling policy framework for gaining consent for whichever projects are in the most appropriate spot.

The reason that we are seeing a lot on heat networks in the NPF4 is that they are a relatively new development in Scotland, and we are aware that many planning authorities have not dealt with applications around them. We want the NPF4 to create that guidance and framework for a planning decision maker when an application comes forward, but we are not looking for the NPF4 to attempt to provide any strategic guidance on what the most appropriate technology is. We are hearing those two things being conflated in policy discussions.

We expect building regulations to deal with what heating should be used in a new property and we expect permitted development rights to enable what needs to retrofitted to an existing property, and, in relation to bringing forward a large new scheme that would need planning consent, we would expect the NPF4 to be a framework that would enable that to happen. We expect the Government’s overall heat strategy to analyse what the most cost-effective net zero-responsive way is to decarbonise our heat demand. However, as I said, we are seeing those two elements that I mentioned beginning to be conflated, which is not helpful.

12:00  

My first question is quite general and is for Kirstanne Land and Dr Kerr. The national spatial strategy focuses on different areas in Scotland. What impact will the strategy have on energy production and consumption? Will it support a radical reduction in greenhouse gas emissions? What are the key barriers to delivering the six principles of the strategy? How can promoting and supporting active travel and decentralising energy networks be delivered justly?

We support the spatial strategy, particularly the inclusion of the transmission network on the spatial strategy map. The map includes the progression of future remote island links, which we think will be important.

It is important to note that the projects that are shown on the map do not include all of the strategic transmission investments that will be necessary to support Scotland’s net zero ambitions, such as reinforcements to the grid network in Argyll and Skye, the east coast high-voltage direct current link and many others. That will change as we make the journey to net zero and need other reinforcements in the network. It is important that there is flexibility.

The priorities that are listed in the spatial strategy are probably the right ones. We are fully supportive of the overarching objectives of NPF4. We think that those are the right things to focus on. We have concerns about the detail of some specific policies, because they do not align with the messaging that is found in the spatial strategy and in the action areas of the document.

I am not familiar with the principles of the spatial strategy, so I will focus on the idea of a just transition and on something that has been mentioned occasionally, but perhaps not properly, in the meeting so far, which is fuel poverty targets. Those targets have been recently revised, with a new definition and a new target date for achievement. Scotland and the rest of the UK have had fuel poverty targets for more than 20 years, but policies have not had much impact. The definition has been revised, which affects how fuel poverty is recorded and reported.

About a quarter of the Scottish population is considered to be in some form of fuel poverty. Addressing that while at the same time moving to low-carbon heating makes a significant challenge even more challenging. It is important to recognise the scale of the challenge, because that will help to focus minds on the most effective means of achieving affordable, low-carbon energy. The fuel poverty targets sit alongside the low-carbon targets and achieving both will be incredibly difficult. The scale of that challenge should focus minds to think in radical ways about how heat and energy are paid for and about how the system is run. It might require radical thinking to achieve both targets simultaneously.

My next questions are for Elizabeth Leighton and Morag Watson. Please also pick up on any of my previous points if you would like to.

Do you feel that the priorities that are set out for each of the five areas in the spatial strategy are appropriate, given that all the spatial principles that we have touched on already also apply to those regions? Is there a lack of clarity for the public and private sectors and communities? If so, how should that be overcome?

We have majored on the clarity issue quite strongly, because we think that, in addition to the framework, there is a lot that the Government can do to show leadership and provide clarity and certainty, not just for the planning system but for investors, as you said.

There is a need to align the spatial strategy and the national developments that are in the framework with infrastructure investment plans and future Scottish budgets to show that there is a genuine plan and commitment to taking those forward and working with the private sector to do so. Some of the national developments that were in previous national planning frameworks did not happen; indeed, some have been carried forward to the NPF4. That alignment is important to provide clarity and to bring in private investment.

I will pick up on Natalie Don’s question about ambiguity. We have no concerns per se about what is in the spatial strategy but, when you look across the sections of the NPF4, you see that they are quite inconsistent. Some mention renewable energy and some do not. As Kirstanne Land said, some major infrastructure projects are not there. When you compare the sections in the NPF4, it is not clear how they relate to one another. It is not clear how someone who makes decisions in the planning system should take what is in those sections into their decision making.

That takes me on to another overarching concern that we have about the NPF4. There are many important priorities in there, as has been mentioned. There is the need to tackle poverty, the need for decent homes, the need for a just transition, the need to protect the environment and the need to address climate change, among many others. However, there is no hierarchy anywhere in the document to give guidance on how to balance those things.

We want all those priorities to be delivered, but we want them to be mutually reinforcing so that we have a joined-up and coherent approach. However, at the moment, there is nothing to join them up and create that coherence. Therefore, we are in danger of all our important priorities competing with and beginning to undermine one another rather than having a mutually reinforcing approach that delivers the Scotland that we all want.

We want a Scotland that is low carbon and has thriving nature, and one where our communities thrive, we have community wealth and a just transition and people no longer live in fuel poverty. However, we do not see how that all comes together in a coherent way from what is currently in the NPF4. We think that it can do that, but the potential has not been realised.

Thanks, both—that is useful to know.

Good morning. Eighteen national developments are proposed, including key developments for the energy sector. The written submission from Scottish Renewables makes the point, which Elizabeth Leighton has just touched on, that several of the national developments from NPF3 have been carried forward to NPF4. Scottish Renewables told the committee:

“designation as a national development provides negligible benefits within the planning system.”

The submission cites the fact that projects from NPF3 were carried over as further evidence that national development designation

“does not work as a planning mechanism.”

I ask Morag Watson to elaborate on that. What are the key barriers to national developments being realised?

There is a developing theme on that. National designation is very welcome and reinforces the importance of those developments, but that does not follow through into the planning system when it comes to how applications are treated in the planning balance. It is not clear how a decision maker should treat a designated national development that comes before them and whether they should treat it differently from any other consenting application. That is the underlying problem.

Things are put into a category, but what that category means is not clear. As you said, projects that were designated as national developments in national planning framework 3 still have not been given consent and developed. You would think that being a national development would confer some kind of advantage in the planning process, but case evidence shows that it does not do so.

We would like that to be addressed in NPF4. If such developments are of national importance to us, we should have a process by which they are treated as nationally important. That should weigh in the planning balance, somehow. How that should happen and how much weight should be afforded to such developments is open to debate, but some weight should certainly be attached to them, which does not currently appear to be the case.

Thank you. Elizabeth Leighton, I mentioned you, so let me turn to you next.

The national developments are not in the programme for government or the infrastructure investment plan—with a few exceptions, such as digital fibre. That makes us wonder how they will happen and what confidence the planning system can have in their significance, when it comes to addressing the concerns that Morag Watson raised.

It is important to see the national planning framework in the context of wider Government decisions in the budget or in the forthcoming national transformation strategy, which is particularly significant in this context. Does everything add up to promote the same picture in order to give confidence not just to planners but to investors?

I will stick with that theme and seek your view on it, Dr Kerr. Will you also say how important the national developments are to energy production and consumption when it comes to radically reducing greenhouse gas emissions, as we hope to do?

I am not aware of the weighting issue, but Morag Watson’s points seem very sensible. If projects that were designated as national developments in 2013 are not yet in development, that suggests that serious consideration needs to be given to the weight that designation carries, but I am not an expert on the matter.

Thank you. What are your thoughts on that, Kirstanne Land?

I support the feedback that other witnesses have given so far. SSEN Transmission obviously very much welcomes the inclusion of transmission infrastructure as a national development in NPF4, because that gives added strength or weighting to a type of development that will be fundamental in supporting delivery of net zero.

That brings me back to the policies in NPF4, some of which are drafted in such a way as to create blockers to national developments going ahead. We can see potential for inconsistency between policies, and some policies do not set out in detail what they want to deliver, which makes it difficult to make consistent decisions.

I talked about the policy on trees, woodland and forestry, which, as currently drafted, could be a huge blocker for transmission infrastructure as a national development. If we have to remove trees, which we try not to do if we do not have to, we always look to replace them. We are supportive of the desire to limit any impact on forestry and woodland.

12:15  

However, there is no flexibility in the wording of the policy at the moment. It is not always possible for us to develop in an area without woodland, because there tends to be woodland cover in our operational areas due to the nature of where we develop our projects in the north of Scotland.

The lack of flexibility in some of the policies is already creating a blocker to the development of national development projects. In the woodland policy in particular, an exception should be made for essential infrastructure when there is a locational need and no other options or sites are suitable. There is no recognition of that in NPF4, and it would be helpful to have that in the context of delivering net zero and national developments in future.

I will aim my final question at Morag Watson, who said that we need to start front loading when thinking about how planning decisions are made and how the public engage with that. Will you elaborate on what the missing link is with that? From my understanding, we have been talking about front loading in planning for a long time. Are resources missing, or is it something else?

One of the key things that we are hearing, particularly from statutory stakeholders, is that there is a capacity issue and that they do not have enough time. It ends up being a catch-22 situation. In planning, there has always been a pre-consultation phase, in which it would be normal for our developer members to test and hear thoughts on ideas with their statutory consultees and their communities. Based on the feedback that developers get, they redesign their schemes so that they address people’s concerns before even going into planning.

When we are constrained and there is a requirement for statutory consultees to respond to planning applications but not to pre-consultations, they will put an emphasis on responding to planning applications, because they have to meet their obligations. The catch-22 then comes in, as the planning applications are not quite what they would have wanted had they been able to engage in the pre-consultation stage. Had they been able to engage at that stage, the applications would probably have been a lot closer to what they wanted.

However, because that engagement does not happen, we have to go back through the process. The application has to be revised and resubmitted, and everyone has to look at it again. If there are more comments from other statutory consultees, another set of adjustments need to be made, and the process goes round again. We end up in a loop and go over the same ground again and again as we make adjustments to meet everybody’s needs. That could be prevented, but capacity is strained, which creates a bottleneck later on. As I said, we find ourselves in a catch-22 situation.

That is helpful. The principles of national developments, given their status, do not need to be agreed in the later consenting process, but they still have to have relevant statutory consent. On paper, it looks as though it should be a quicker process, but there might be other reasons why some projects are not getting off the ground.

I am conscious of time, so I will hand back to the convener.

Thank you.

I will go back to an earlier question about the Scottish Government’s offshore wind policy statement, so that I can get more clarity. Some witnesses agreed that changes need to be made to align NPF4 with the OWPS, but they did not say what those changes should be. I would like to dig down into that a little more. I cannot remember who said that changes need to be made, but I ask Morag Watson for her comments first.

As we move towards net zero, our offshore wind industry will become the backbone of our energy generation infrastructure. That energy will all have to come onshore, and there will be operations and maintenance centres and so on. The strategies and the spatial area plans that are in NPF4 often do not include the huge amount of offshore development that will happen adjacent to those areas.

As Kirstanne Land said, grid infrastructure will be important as we bring all the electricity that is generated, particularly in the northern North Sea, into the east coast. We will need grid infrastructure that can transport that electricity to where it is needed. Again, we are not seeing joined-up thinking about what we will need to consider as we move towards 2045.

This might be an unfair question, but how do you see that developing? What is needed for that to happen?

In terms of the practicalities, we need to get that written into NPF4 and simply included in the policy. That is the first step, so that everybody, including the planners, is aware that that is happening and that it will develop over time.

As we have said in many places, there needs to be guidance on how such matters should be treated in the planning balance. Offshore generation capacity will be key to Scotland’s low-carbon energy generation in the future. It is also key to our just transition, as we transition from a fossil fuel-based energy system, on which much of our economy depends, into one that uses renewables.

That will be very new for our planning decision makers; they will often not have come across it before. They will be looking for NPF4 to provide them with guidance on how they should be thinking about such matters, what kind of decisions they are expected to make, and how they should weigh those decisions against other considerations in the planning balance. That is what is missing.

Thank you. Does Kirstanne Land have anything to add?

I agree with everything that Morag Watson has said. Our company is responsible for connecting the projects. ScotWind will be a huge focus for our business, and co-ordination is particularly important not only to connect the projects in the most efficient way but to reduce the impact on communities wherever possible. I think that what Morag Watson said is right.

Do we need some regional frameworks, or should it all be national? Some regions might have different needs from others.

NPF4 touches on that point. The document seems to have split up different regions with different priorities. From looking at the detail in NPF4, we do not have any huge concerns about what is proposed. However, certain generic priorities are featured in some areas but not in others—for example, biodiversity is referenced only in a couple of the action areas; it is not in all of them.

Transmission infrastructure is also not referenced across all areas. I think that there is reference to it only in relation to the islands, which makes sense, as that is a key focus in improving resilience and supporting their journey to net zero. However, we think that the transmission network should be recognised across all the action areas in Scotland, because it will play such a key role in the transition to net zero, and I do not think that that is recognised at the moment.

Thank you.

I will just follow on from that—I will turn to Kirstanne Land first. In previous iterations of the NPF, we have had specific transmission projects such as the Beauly to Denny project being cited as national developments. It seems that NPF4 is a bit light on detail regarding specific infrastructure projects that are needed and where they are going to be. I am thinking about 25GW from ScotWind, 10GW from onshore wind and maybe 6GW—I do not know—from solar. As a transmission business, is SSEN Transmission looking at the plan and thinking, “There are five bits of major chunky transmission infrastructure that need to be written into it,” or is the wording and detail currently enough?

It is important that the wording remains quite flexible. As you said, a lot of investment in the transmission network is required, and we currently have priority projects that we, as a business, are keen to take forward. For example, the east coast HVDC link will be crucial to deliver ScotWind projects; we are also looking to take forward investments in Argyll and Skye, as well as connection of the islands, which Western Isles and Orkney are keen for us to do.

As further investments and projects are needed in order to meet renewables targets, we might find that more projects come on board that we need to progress. NPF4 does not currently refer to named projects, but those projects—not just projects for transmission, which are key, but others—are drawn on the map. In addition, there are equally important projects that are not included in NPF4. It is right that we keep that flexibility because it gives us the ability to progress other investments that need to happen. If NPF4 simply listed key projects, that could be problematic for future investment.

Is there potential for conflict, and a potential limit on capacity for transmission? We may have projects competing against each other, with onshore versus offshore versus solar. Is that a realistic prospect, or does NPF4 allow everything to be built out?

It depends, project by project. We rely hugely on the planning process in order to take forward our projects and ensure that they are delivered in a timely way, and that is one of the factors that we look at in delivering them. As long as NPF4 supports the delivery of transmission infrastructure, making a couple of tweaks by rewording some of the specific policies in there, in particular on the biodiversity and woodland policy side, would make a huge difference in removing some of the blockers. That can be delivered if NPF4 is tweaked a little bit.

Scottish Renewables has been calling for NPF4 to have a much stronger relationship with other Scottish Government policies, in particular around energy and net zero. We expect NPF4 to govern planning for 10 years, and we know that, during that time, there will be a lot of dynamic change. As new information comes from the United Kingdom Climate Change Committee and from advice and research, the way in which we move towards net zero will have to evolve and change. One of our key concerns is that, if we start, as Kirstanne Land said, to put specific things in NPF4, we might realise, as more data comes forward, that those things need to evolve and change. NPF4 needs to be flexible enough to accommodate such change as we move forward.

It is very helpful that the Scottish Government is starting to set targets. For example, it is consulting on a target for onshore wind, and it is starting to look at a strategy for solar energy in Scotland, which we hope will include a target. That gives our planning decision makers an understanding of the scale of what it is that needs to happen. Likewise, it gives us an opportunity to monitor how we are progressing towards those targets and whether planning is an enabler or a blocker. If it proves to be a blocker, that gives us the opportunity to evolve our policies and advice and ensure that it no longer acts in that way.

As Kirstanne Land said, SSEN, as a business, has a clear plan for what infrastructure is needed. Through the ScotWind process, for example, we know what the future pipeline looks like, and we will know what the pipeline looks like for onshore wind. We need to be able to support and facilitate those things, rather than having planning become a blocker to them.

12:30  

In its submission, Scottish Renewables said that visual impact is the main reason why renewables applications are turned down. What changes to how projects are assessed is the industry looking for? Who is responsible for that—is it NatureScot? You briefly mentioned wild land. Are you looking for a change to how landscape is assessed? The major point of contention—if there is one, as the public strongly support onshore wind—seems to be visual impact; that is the main reason why projects are turned down or why it takes a long time for them to get through the planning process. What changes are you looking for?

You ask a really interesting question. When we look at why planning applications—particularly for onshore wind—have been turned down, we see that visual impact is the reason in the vast majority of cases. As the industry body, Scottish Renewables has commissioned independent research, as has the UK Government. Such research has consistently found that public support for onshore renewables and particularly for onshore wind sits at about 70 to 80 per cent. When we survey people who live within 5 miles of a wind farm, we find very high levels of public support—people do not seem to be concerned about how wind farms look.

A recent report from Biggar Economics looked at whether the presence of wind farms impacts on tourism, because we know that that is a big concern in relation to how they look. The report found no relationship between wind farms and tourism, and it found that tourism levels had gone up in areas with more wind farms.

Visual impact has a disproportionate weight in the planning balance, which brings me back to the first point that I made. NPF4 contains no guidance on how we should consider climate change and the climate emergency in the planning balance. We know that we need more onshore renewables to hit our targets and we know that we will need to consent projects, but if we keep refusing wind farms because a minority of people object to how they look, we will never reach our targets.

The Scottish Government says in NPF4 that we must radically change the planning balance, which we all agree needs to happen. The Government has set all the right priorities for rebalancing the system, but I return to the original point that there is no guidance on how that should happen and how a planning decision maker should do that. Such guidance is essential to stop the disproportionate skewing of the planning balance in decisions.

Is addressing the materiality of climate change vis-à-vis landscape the primary way of rebalancing decision making? Do other aspects apply? Community economic benefit has been proposed in the past as a material consideration in planning.

Material considerations in planning are interesting and come up a lot. To explain that for people who are less familiar with the legal aspects of decision making, material considerations are a group of things that are placed in the decision-making basket and are balanced against one another. That has been a prudent approach in our planning system to date but, as Elizabeth Leighton said, now that we are in the climate emergency, our thinking needs to move to an emergency stance.

Climate change is not equal with all other considerations; it is a serious threat to us as a nation and more widely. We were one of the first nations on earth to declare the climate emergency, which we are taking seriously. That needs to be reflected in our planning decisions; we cannot treat climate change as just the same as all other considerations, any more than we can do so with the biodiversity emergency.

As the Scottish Government has said, such matters need to be the prime considerations in decision making, but we need guidance on what that means. We need to start consenting things that will move us towards net zero. There is also a question mark over whether we should cease to consent things that would increase our emissions. Guidance on decision making and on the balance is needed for that.

I have another couple of brief questions. One question is to wrap up this subject, so I will stay with Morag Watson and then invite others to speak if they want to add anything. Earlier, you mentioned some of the constraints in local planning in relation to capacity and resources. Is there also an issue in respect of the Government processes for section 36 and section 37 planning consents, or is it just a problem for local authorities and their role as the planning authority for smaller developments that do not meet the threshold?

We have seen a big issue with timescales in the section 36 process. Although there is guidance on how long the public local inquiry should take, there is no guidance on how long the reporter should take to write up the report once the inquiry has taken place, and we have no timescales for how long the minister or cabinet secretary should take to make a decision on the basis of the report from the reporters. During the pandemic, we saw that decision-making process following a public local inquiry stretch from nine months to 27 months.

At the moment, the timeframe for making a decision around planning from the first conception of a project to consenting is seven years. We have eight years to hit our onshore wind targets. The two do not go together.

In England, there is a three-month timeframe for the reporter to write their report and then a three-month timeframe for the minister or cabinet secretary to make their decision. It would be exceptionally helpful if those kinds of timeframes were established in Scotland.

I cannot see how any project is investable if it takes seven years to get a decision.

Does Niall Kerr or Elizabeth Leighton have anything to add to that? I know that it is not in your direct expertise.

I have two points. The first is on the balancing language. I pulled out a couple of points from the text of NPF4, which talks about what should not be supported and about ensuring the

“level of emissions is the minimum that can be achieved for the development to be viable and it is also demonstrated that the proposed development is in the long-term public interest.”

One might question how something that will increase our emissions or not support our transition to net zero can be in the long-term public interest. That is an example of the type of language that is not as helpful as it should be in giving a strong push on the significant weight that should be given to the climate emergency. That is just one example.

I want to give another example, which is about the leadership issue and giving more confidence to the planning system. We have called for the Scottish Government to make a statement that it will call in major developments where it believes that the climate impacts have not been properly considered. That would relate to emissions reduction as well as adapting to climate impacts. We think that that would send a strong message to planners that, if they are making decisions that they think are risky in the way we think of planning now, they will be backed up and that, if they do not make those decisions and it is business as usual, they will be called out. That is an important leadership role for the Government.

Thank you. Niall, do you want to add to that?

I have no specific points to make on those issues.

Dr Kerr, I have a final, brief question for you. The Scottish Government is creating the public energy agency to help to implement the heat in buildings strategy. However, it will be only a virtual agency, with no additional budget or resource, and it will not be up and running until 2024. Is that enough resource and support to meet the 2030 heat in buildings targets?

A point that was made about that earlier was that things are on-going that do not rely on the national public energy agency. There are Scottish incentive schemes and regulations coming in and they will not rely on that public energy agency.

However, bearing in mind what I was saying about the challenge of low-carbon and fuel poverty targets, I think that it is important for people to be aware of the scale of that challenge. Given that, it might be more critical for a co-ordinating body—whether that takes the form of the public energy agency or something else—to be prioritised and brought in quicker. It is important to think about the role that such a body might have—the Scottish Government is doing that at the moment. Considering the scale of the challenge, it is fair to say that, if the body is to play a critical role, it should be established as soon as possible.

Thank you very much. That brings us to the end of our questions. I thank the witnesses for joining us this morning and giving us their time. Enjoy the rest of your day.

Next week, the committee will have one more evidence session on NPF4, looking at transport, the environment and the circular economy. We will share our findings with the lead committee towards the end of the month.