Consider only areas which fall within existing National Scenic Areas

Response to Q4: What criteria should we use to decide where the next new National Parks in Scotland should be?

In designating any new National Park or Parks, The Scottish Government must balance its ambitions to increase the number of National Parks in Scotland with the need to deploy more renewable energy to meet our legally binding target of reaching net-zero by 2045 and the binding interim targets for 2030 and 2040. To realise the enormous environmental, economic and social benefits that both National Parks and renewables can bring to Scotland it is our recommendation that only areas which fall within existing National Scenic Areas should be considered.

Why the contribution is important

Scotland’s planning system determines where renewable energy generation technology can be deployed and is critical to determining whether enough energy can be generated to meet our legally binding target of reaching net-zero by 2045 and the binding interim targets for 2030 and 2040, as well as realising the economic and social benefits renewables offers.

Planning policy states that wind farms will not be built in either National Parks or National Scenic Areas. The renewables industry supports this policy.

To keep Scotland on track to achieving net-zero, we will require an additional 11GW of offshore wind, at least 12GW of onshore wind and 4GW of solar by 2030 to provide the electricity to decarbonise heat and transport. Achieving an additional 12GW of onshore wind will deliver fresh economic opportunities for Scottish supply chain and ports, creating £27.8 billion in GVA and 17,000 jobs across Scotland (Onshore Wind Industry Prospectus, October 2021).

• Creating a National Park in an area that is not currently covered by any designations that precludes wind farm development, will have significant ramifications for meeting Scotland’s renewable energy targets, and pose a direct conflict with the priority given to the Climate Emergency, as seen in draft NPF4.

• It will not be possible to repower any wind farm already sited in a newly designated National Park. This will mean that, over time, there will be a loss of generation. Resulting in a loss of opportunity for increasing generation with larger and more efficient turbines typically seen with a repowered site.

• There could be a loss of opportunity to life extend existing assets, therefore wasting the opportunity to maintain output at an operational site.

• Communities currently in receipt of community benefit payments will lose this income stream from wind farms, where they could otherwise have continued to receive this via a repowered scheme.

• There may be wind farm projects not yet determined at earlier stages of the development process in a new designated National Park which are no longer viable, meaning a significant financial loss to developers and future investor confidence.

Scottish Renewables would be keen to engage further with this agenda and would be happy to discuss our response in more detail.

Scottish Renewables is the voice of Scotland’s renewable energy industry. Our vision is for Scotland leading the world in renewable energy. We work to grow Scotland’s renewable energy sector and sustain its position at the forefront of the global clean energy industry. We represent over 300 organisations that deliver investment, jobs, social benefit and reduce the carbon emissions which cause climate change.

by ScottishRenewables on May 27, 2022 at 11:29AM

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Comments

  • Posted by GallowayHoopoe May 31, 2022 at 08:36

    We need a nationwide discussion of this issue before a moratorium is effectively placed on new internationally recognised designations. Despite being a very beautiful country Scotland is under-designated compared with other European countries with its two existing national Parks.

  • Posted by NicBullivant May 31, 2022 at 10:41

    Quite a good idea, but do the existing NPs only occupy NSAs? And NSAs are an old designation introduced to avoid the 'need' for NPs, and do not take into account the four aims of Scottish NPs.

  • Posted by camusfearna May 31, 2022 at 12:23

    The comments by Scottish Renewables are very sensible and reflect important points that need to be considered when any area is considered for national park status - can Scotland afford to carve out further areas where no windfarms can be considered and would existing windfarms in an area subsequently designated as a national park require the removal of the windfarms and the associated community funding.

    I would add that as National Scenic Areas were designated specifically for their landscape character, without consideration of other factors or criteria, most or all of them would be unlikely to meet the criteria to be designated as a national park.

  • Posted by camusfearna June 04, 2022 at 10:24

    Any area being considered for designation as a new national park should be looked at in relation to maps of windfarms that are operational, under construction, approved and proposed. Ministers will need to decide whether a national park could be established with windfarms within its proposed boundary (contrary to Scottish Planning Policy) or if operational and under-construction windfarms in the area would need to be removed and approved windfarms de-approved. This would come with legal challenges (and possibly compensation claims) and the need to identify alternative equivalent sites in order to maintain Scotland's progress to meeting its renewables energy plans as part of its wider statutory climate change commitments.

    These issues unfortunately have not been addressed by those campaigning for one or more areas to be designated as a new national park.

  • Posted by scottishwildlandgroup June 04, 2022 at 14:53

    The introduction to this "idea" seem to be based solely on one issue - windfarms.
    The consideration of National Park status should be anywhere and not limited to just those places with a NSA designation providing it meets the criteria set out in the National Parks (Scotland) Act. Wind generation is not the only source of carbon free electricity and this needs to be considered in this discussion. We agree there should be, and should have already been, a discussion between Scottish Renewables, The Scottish Government, and all bodies with an interest in the Scottish landscape to work out an agreed way forward for power generation. There is a balance to be struck but the destruction of our iconic landscapes ( and once gone they are gone forever) is not acceptable when it can be avoided.

  • Posted by camusfearna June 04, 2022 at 20:00

    It would be interesting to hear from the Scottish wild land group and others if they have a view on whether a national park should be sited where there are existing, under-construction and approved windfarms, that would mean a national park had windfarms within its boundary; or if they would propose the removal of constructed and under-construction windfarms in an area proposed for NP designation and the de-approval of any approved windfarms in the area.

    It makes sense in terms of consistent planning policy and Scotland's statutory climate change targets that any candidate areas for national park designation comply with these requirements and are considered in areas already designated a National Scenic Area (and thus an area in which windfarms currently are prohibited).

    This seems to be a key criteria to be considered.

  • Posted by AndrewPym June 05, 2022 at 21:43

    It is not enough to rely on UNESCO Biosphere designations or on National Scenic Areas. Neither convey the message that the area designated as a National Park is of the highest quality of interest for national and international travelers. That is not to say that the area is unblemished: motorways, mineral workings and other large scale intrusive activities are to be found in many National Parks: e.g. slate mining in Snowdonia and the M6 through the Lake District. The designation allows people to know that there is much to see and enjoy in an open rural environment.

  • Posted by camusfearna June 06, 2022 at 00:11

    Respectfully, the comment above by AndrewPym misses the point of earlier comments. A national park designation is indeed special and thus should be considered very carefully including in relation to the long-established position in Scottish Planning Policy that national parks in Scotland do not have windfarms in their boundaries.

    The reference to National Scenic Areas to help identify potential areas for national park designation is because under Scottish Planning Policy there are no windfarms in NSAs.

    Any areas where there currently are windfarms (or they are under construction or have been approved) should not be considered for national park designation.

    This is absolutely not arguing that national parks should be unblemished or pristine - national parks in Scotland (and elsewhere in the UK) are working landscapes where people live, work, visit, recreate, farm, and there are businesses, roads and other infrastructure.
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