SWLG responses to Government consultations on National Planning Framework (NPF3) and Scottish Planning Policy

July 2013

The SWLG responses to the Government's consultations on the draft National Planning Framework 3 and Scottish Planning Policy are available for download below:

National Planning Framework

Scottish Planning Policy

We believe that both documents are far too biased in favour of industrial wind farm developments and offer very little meaningful protection to sensitive environments or wild land. Both will favour short-term financial gain by large companies and landowners while disempowering local communities and undermining Scotland's long-term economic and environmental prospects. The main points in our responses are:

  • That the Government's 'overall purpose' of achieving sustainable economic growth is poorly defined and, in practice, means that short-term economic benefits will be prioritised over longer term economic, environmental and social factors.
  • That it is inappropriate for planning policy to be used to achieve one set of policy targets (the expansion of renewable energy developments) when its role should be to balance competing interests and requirements for land use.
  • We support the proposed protection of National Parks and National Scenic Areas from wind farm developments, but believe that this protection should include any large industrial developments, and that it should extend to 'core areas' of wild land and incorporate buffer zones around sensitive landscapes. Local and regional designations should also be better respected.
  • That a coherent strategy for renewable energy developments is urgently needed, to end the overloading of the planning system by speculative proposals.
  • That peat lands represent a priceless environmental resource and carbon store, and should have stronger protection.
  • That establishing a National Ecological Network to link protected and semi-natural areas would bring considerable benefits, not least in terms of mitigating the effects of climate change, and should be a priority.
  • That the conditions for allowing damaging developments in protected areas should be clearer, and should not include subjective terms such as 'substantially', 'significantly' or 'satisfactorily', which are very hard to interpret in practice.

We also submitted an open letter to the Government with seven other Scottish environmental organisations.