Last week, representatives of community councils from across Scotland travelled to Holyrood for a roundtable about the issues facing them from the acceleration of energy infrastructure in rural areas, and the overwhelming volume of planning applications they are dealing with.
I spoke for my allotted three minutes, as a representative of APRS, alongside community councillors from as far afield as Skye, Strathy and Galloway, about our research showing that there are already three times as much consented Battery Energy Storage Systems (BESS) than we need for the UK’s net zero pathway, according to the National Energy System Operator (NESO) figures. If you add in those in the planning pipeline – then we are up to five times overprovisioned.
A battery energy storage system consists of several large batteries that store electrical power for use at a later time. They can be charged using excess electricity generated by wind or solar farms, for example, or by grid connection during periods of lower demand.
I’ve written before about how, were Scotland’s environmental charities to join with community councils, we would have a powerful coalition for changing our current dysfunctional energy consenting system. Scottish Environment LINK and their member environment charities have been campaigning for spatial planning for renewable energy for two decades, for equal right of appeal so communities can appeal planning decisions, just as developers are able to do, for communities to be the key stakeholders in the planning process, and for much much, more community and municipal-owned energy generation.
The failure of Scottish Government to meaningfully implement these is at the heart of the issues in rural Scotland with applications for energy projects backing up, with no plan or strategy behind it, swamping community councils who, as volunteers, are expected to read hundreds of pages of technical documents for each application.
The issue seems intractable. The cabinet secretary suggested this week, in the National, that these community councils were listening to ‘far right narratives’ in their assertion that there must be a better way to do energy planning and consenting – one that looks ahead and makes a plan, that has space for local democracy to work, and that works for communities, local landscapes and local business.
But amongst the lacklustre policies, there is a hint of possibility. As well as the Scottish general election approaching, with this issue sure to become a key issue in Scotland’s rural areas, the Scottish Government is currently planning to change something that may seem like a technical detail in the consenting process, but could actually be transformative.
This is the suggestion of changing the threshold for planning applications to go to Energy Consents Unit (ECU), part of the Scottish Government, for decision-making. At present, any energy generation or BESS proposal above 50MW is decided by ECU, but the Scottish Government is consulting on whether this should be raised.
Currently all Battery storage projects in England are decided on by Local Authorities and our Battery storage report concluded that should be the case in Scotland, and that they should be part of Local Development Plans, the spatial plan created by Local Authorities, for how land use and development will change in the area over the next decade. But we believe it shouldn’t stop there. If the responsibility for all onshore consenting for energy went to local authorities, this could change everything.
It would mean that the decision making process becomes more transparent and more accountable to local people and local democracy. And it would ensure that local planning departments were adequately resourced.
At present, planning authorities still need to assess all energy applications over 50MW and report that to ECU, despite not receiving any of the planning fee (£70,000-280,000). If local authorities are making the decisions, they have a marginal amount of extra work but they will receive the payment. It also means they will avoid triggering a public local enquiry (which they also have to pay for) if they choose to object to a development.
And having energy infrastructure consent as a local planning authority decision will ensure that the principles and policies of National Planning Framework 4 (NPF4) are upheld in the decision making process, which at present, as our research showed, they are not.
Although all of these are really positive things in themselves, this is not the transformational bit. It is including energy developments in Local Development Plans (LDPs) which will radically change energy planning decision-making. Including energy generation and storage in LDPs will ensure a plan-based approach for energy, just as we do for all other developments.
At present, ECU are not making decisions according to any kind of spatial plan or strategy, they are not even, as we found in our research, taking notice of NPF4. LDPs would ensure that the right national and UK bodies input to the spatial plan, including NESO, the energy networks companies, and importantly would ensure that community energy projects could be prioritised in decision making, which they cannot be at present.
We hope that communities and individuals across rural Scotland, struggling with an energy consenting system which doesn’t work and has no strategy or plan, will see the opportunity for change and input to this consultation from the Scottish Government.
Image Credit: Thomas Richter for Unsplash
