Renewable and Low Carbon Energy Supplementary Guidance
Perth and Kinross Council · 27 August 2025
Back to Economy and Infrastructure Committee — 27 August 2025 and its agenda
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Our vision is a Perth and Kinross where everyone can live life well, free from poverty and inequality ___________________________________________________________________ Committee or Board: Economy and Infrastructure Date of Meeting: 27 August 2025 Report Title: Renewable and Low Carbon Energy Supplementary Guidance Report Number: 25/212 Report Author: Robert Wills, Planning Officer, Development plans team Organisational Lead: Serge Merone, Strategic Lead – Economy, Development and Planning ___________________________________________________________________ 1. Purpose 1.1 This report presents the most recent draft of the Renewable and Low Carbon Energy supplementary guidance for planning proposals (the draft Guidance). Planning guidance does not form part of the development plan. When relevant to a decision, the guidance will be a material consideration to be afforded such weight as determined by the decision maker. This report provides a summary of changes necessary since the previous draft due to the introduction of National Planning Framework 4 and current practice. The report seeks consent to proceed to public consultation. 1.2 Sections 1. Purpose 2. Recommendation 3. Background/Main Issues 4. Impact and Value Assessment 5. Appendices 2. Recommendation 2.1 It is recommended that the Committee: • Approve the draft Renewable and Low Carbon Energy supplementary Guidance and Strategic Environmental Assessment screening report to proceed to public consultation.
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3. Background/Main Issues 3.1 Historic Information/Context 3.1.1 The Renewable and Low Carbon Energy supplementary guidance was first produced and consulted on in 2016 as statutory guidance. An updated draft was further consulted on in 2019. These drafts were not finalised due to concerns from key agencies with regards to landscape sensitivity mapping which did not provide for interrogation of the underlying layers. 3.1.2 National Planning Policy as set out in National Planning Framework 4 (NPF4) superseded Scottish Planning Policy in February 2023. NPF4 also supersedes policies in LDP2 where they are incompatible. Some LDP2 policies, or parts of policies, remain in force where they are compatible with NPF4, for example by providing local detail or filling a policy gap. This means that both NPF4 Policy 11: Energy and parts of LDP2 Policy 33: Renewable & Low Carbon Energy are in force. 3.1.3 The Planning (Scotland) Act 2019 also removed planning guidance as part of the development plan. The draft Guidance can therefore not override National Planning Policy in NPF4, nor introduce new policy. The draft Guidance does however set out how policy will be interpreted and the information required by decision makers in Perth & Kinross to determine whether current policy is satisfied. 3.1.4 The draft Guidance is not an indication of future policy in the next Local Development Plan (LDP3). Any new policy will be introduced through LDP3. Further engagement will be carried out with members, stakeholders and communities as part of the LDP3 proposed plan preparation to inform future policy. 3.1.5 The draft Guidance therefore sets out the Council’s interpretation of current planning policy and the information expected to be submitted by applicants to allow a fully informed determination of applications. Need for Updated Guidance 3.1.6 The Guidance is based on established best practice and policy interpretation. Much of the best practice guidance and the intent of policies remains the same to previous drafts. However, there have also been substantive changes which require the draft guidance to be updated. 3.1.7 NPF4 introduced a more supportive approach to renewable energy. In summary these changes include: • The removal of a spatial framework for wind, • The significant weight to be given to the Climate emergency in NPF4 Policy 1, • The expectation of significant adverse landscape impacts from some forms of renewable energy, • Express provision for renewable energy installations on prime agricultural land, carbon rich soils, flood risk areas and the greenbelt.
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3.1.8 The draft Guidance sets out the Council’s expectations as to how these policies will be interpreted and the evidence required by proposals. 3.1.9 Some NPF4 policies also introduced complexity and uncertainty. Where relevant, the preferred policy interpretation of these policies is set out. This includes biodiversity enhancement in NPF4 Policy 3, the definition of renewable energy as “essential infrastructure” in several policies and the introduction of a requirement to “maximise net economic impact”. 3.1.10 The Guidance requires a statement of net economic impact to include those elements set out in Policy 25(a) Community Wealth Building. This addresses issues such as employment, training, business and utilising local supply chains. Opportunities should be explored with local communities and address local priorities such as those set out in Local Place Plans. 3.1.11 It should be noted that “community benefit” is a consideration separate from planning which typically involves a monetary payment to a community fund, but can also include community ownership of a scheme or discounted power. Community benefit cannot be taken into account in planning decisions. A separate members’ briefing note distributed on 6 July 2025 discusses community benefit in more detail. 3.1.12 Since the previous draft, and with the introduction of NPF4, there has been an increase in applications of Battery Energy Storage Systems (BESS). Experience of these applications and additional guidance with regards to fire safety has informed the guidance for these applications. 3.1.13 In addition the land use requirements of solar and BESS installations has required an increased focus on cumulative impacts. The draft Guidance ensures that applicants provide decision makers with information describing cumulative impacts on soils, landscape and noise. 3.1.14 The draft Guidance emphasises that the cumulative loss of prime agricultural land must be addressed in planning applications and requires demonstration of specific locational needs, no other non-prime site being available and consideration of alternative sites. Applicants are asked to quantify the loss of prime land from their application. This is intended to provide greater certainty for decision making. As noted above, policy changes such as how much loss of prime land is acceptable cannot be introduced by the draft Guidance but can be considered through the preparation of LDP3. 3.1.15 Engagement to Date 3.1.16 The previous draft guidance on which this guidance is based was a result of extensive engagement with key agencies, internal consultees and a public consultation. 3.1.17 NatureScot and SEPA have been engaged with to assist in clarifying specific areas of concern leading to improved clarity in interpretation. 3.1.18 Engagement with elected members has been carried out leading to additional information being introduced in this report on cumulative impacts, net
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economic impact and community benefit. At a members briefing for LDP3 these topics were also discussed and a briefing note distributed on 6 July. 3.1.19 Consultations have also been carried out on specific areas of interest with: • Biodiversity/Tree Officer • Flood Team • Development Management • Environmental Heath • Development Plans Team • Transport Planning • Community Greenspace • Conservation Team • Elected Members • NatureScot • Highland Council and South Lanarkshire Council (due to a shared interest in BESS applications). 3.1.20 NatureScot, Historic Environment Scotland and SEPA were also consulted on the screening assessment resulting in the Strategic Environmental Assessment screening report. 3.2 Rationale for Recommendations made in Section 2 3.2.1 By approving the draft Guidance for public consultation, the Committee will ensure that wider input can be made to the interpretation and information requirements set out in the Guidance from the expertise and experience of communities, renewable energy providers, NGOs and key agencies. This will help to provide a robust framework to ensure complete, consistent information for fully informed decision-making. Members may provide further input during this public consultation period if desired and the resultant amended Guidance will be further subject to committee approval and adoption. 4. Impact and Value Assessment https://www.pkc.gov.uk/media/53970/Renewable-and-Low-Carbon-Energy- Supplementary- Guidance/pdf/Renewable_and_Low_Carbon_Energy_Supplementary_Guidan ce.pdf?m=1745935591020 5. Appendices 5.1 Draft Renewables Guidance (2025) 5.2 SEA Screening Report