As we come to the end of another year and are looking forward to the one ahead, here’s this quarter’s round up of what’s been happening in the world of planning at a national level, and in the key sectors in which we operate…

RTPI campaigns – the big date in the diary this quarter was World Town Planning Day – celebrated annually on 8 November, and marked this year by the Royal Town Planning Institute (RTPI) launching its ‘It Takes Planners &’ campaign. With the aim of tackling misinformation and celebrating the vital role that planners play, everyone is encouraged to share stories about how planners make a difference, as well as the challenges they face. You can watch the RTPI’s video calling on people to change the way we think about planners here, with further information about the campaign available here. As planners, we would of course encourage you to support the campaign, and to share any positive stories you have, using the hashtag #PlannersAnd.

In addition, on 7 December, the RTPI launched Planning is Global 3, the latest in a series of internationally focused publications showing how planners around the world are taking on one of the toughest challenges facing humanity today – how to respond to water in a changing climate, from flooding to drought to rising sea levels. The publication can be downloaded in full or accessed in sections here and is on our holiday reading list!

Chief Planner update – at the end of November, the Planning Minister (Joe FitzPatrick MSP) and Chief Planner (Fiona Simpson) provided an update on recent progress and future priorities for the reform of the planning system in Scotland. From which, the key take aways (in our view) are that:

  • work on implementing National Planning Framework 4 (NPF4) continues to progress, with a second iteration of the NPF4 Delivery Programme published in September;
  • it is re-emphasised that conflicts between NPF4 policies can be expected, and indeed that is normal, with it necessary to weigh up all relevant policies and factors in applying planning judgement;
  • good progress is being made on the production of guidance to support the biodiversity aims of NPF4 (per Policy 3 – for more on which, see below) and work on planning and climate change guidance has commenced, including –
  1. publication by the Scottish Government of independent research on Approaches to Measuring Biodiversity in Scotland, the findings and recommendations of which set out pragmatic next steps to ensure a consistent, cross-government approach to measuring biodiversity at site level, and
  2. that NatureScot will shortly commence work to develop an adapted biodiversity metric suitable for use in supporting delivery of NPF4 Policy 3b) (which states that development proposals for national or major development, or for development that requires an Environmental Impact Assessment, will only be supported where it can be demonstrated that the proposal will conserve, restore and enhance biodiversity, including nature networks so they are in a demonstrably better state than without intervention), engaging closely with all relevant stakeholders in doing so.

Biodiversity guidance – in terms of the work to produce guidance to support the implementation and delivery of NPF4 Policy 3 (Biodiversity), the end of November also saw the Scottish Government publish Draft Planning Guidance: Biodiversity. This has been prepared with advice provided by the Chartered Institute of Ecology and Environmental Management, the RTPI, Heads of Planning Scotland, the Improvement Service and NatureScot, and highlights the critical role of the planning system in increasing nature recovery in Scotland. It also emphasises that, while a universal biodiversity metric is still to be prepared (as noted above), this should not frustrate or delay decision making meantime. Rather, a flexible approach is to be applied, including using information and evidence gathered to satisfy other assessment obligations (such as an Environmental Impact Assessment) wherever relevant and applicable, or using other established metrics or tools where appropriate. Also importantly, the Guidance is written and designed to be a living document, which is to be updated as practice beds in across planning authorities. Meanwhile, the Scottish Government has invited feedback on how the relevant policy requirements are being implemented, and how the Guidance is assisting in that. So, if you have any feedback, please email with any comments.

Digital telecommunications guidance – hot off the press is the Scottish Government Planning Guidance: Digital Telecommunications which explains the role that the planning system has in the delivery and enhancement of digital telecommunications infrastructure. With good telecommunications now being vital to how we live, work and play, and something we largely take for granted, this Guidance is to be welcomed, particularly for those communities which are less well connected. The Guidance again assists in the delivery of a number of the aspirations of NPF4 in terms of tackling climate change, unlocking opportunities for business and employment, supporting investment, ensuring connectivity and facilitating more sustainable ways of living, with the Scottish Government committed to ensuring that all premises in Scotland have access to superfast broadband. It explains the role and processes involved in the delivery of digital communications infrastructure (including the circumstances in which permitted development rights apply and the prior approval process), provides good practice on the siting and design principles of such infrastructure, and a summary of the technical and operational features of the equipment. Whilst not constituting planning policy, the Guidance is a material consideration in the determination of planning applications and should therefore be of interest to a wide range of stakeholders.

Renewable energy related developments – this quarter has again seen a number of notable planning applications for renewable energy related developments either submitted or approved, including:

  • Kinnell solar array – amongst our own projects, we are delighted to have secured planning permission for the installation and operation of a solar farm on land at Kinnell, near Arbroath, for our client One Planet Developments Ltd. With an export capacity of up to 10MW, this will contribute to meeting the Scottish Government’s commitment to increasing the contribution that solar energy makes to the country’s energy mix, while also being accompanied by considerable landscape and biodiversity enhancements, including over 25 hectares of species rich wildflower meadow grassland;
  • Hill of Fare wind farm – following a high-profile public consultation exercise last year, and having reduced the scale of the proposals as a result of concerns raised, an application for consent under section 36 of the Electricity Act 1989 was submitted to the Scottish Government at the beginning of November for a 16 turbine wind farm and associated battery storage at Hill of Fare, near Banchory. With ground to blade tip heights ranging from 180 to 200m and an installed capacity in the region of 205.6MW (including approximately 100MW of battery storage), the project is billed as able to result in the saving of approximately 69,000 tonnes of carbon dioxide equivalent emissions per annum. However, there may still be concerns about the scale of the development, particularly given its proximity to Banchory (it being less than four miles away), and it will be interesting to see how these considerations are balanced in the application being determined; and
  • third Loch Ness pumped storage hydro – November also saw the submission of a section 36 application for a pumped storage hydro scheme on the south side of Loch Ness, with Loch Kemp to be used as the upper storage reservoir and Local Ness as the lower storage reservoir. Of course, this is not a renewable energy project in its own right, but this would extract, store and release energy to and from the grid as required to help balance supply and demand, thus enabling the grid to make better use of renewable energy sources.

There is though another side to the story with regards to applications for renewable energy related developments generally. And, while the above developments are welcomed, the Association for Renewable Energy and Clean Technology’s recently published annual report concludes that it will continue to be a challenge for the UK to meet its legally binding net zero commitments unless more supportive Government policy measures are forthcoming. So, it seems more still needs to be done…

Sutherland Spaceport – as noted in our September bulletin, we have a keen and active interest in the development of spaceports in Scotland, not least because of our involvement in securing planning consent for the Sutherland Spaceport (the first Scottish spaceport to receive consent, and the construction of which is currently underway). Now, as operational requirements for the Spaceport are being fine-tuned, a number of changes to the approved scheme are proposed, with these to further reduce any environmental impacts of the Spaceport during both construction and operation. We submitted a Proposal of Application Notice in respect of these changes to The Highland Council on 2 November 2023 and, after carrying out pre-application consultation, are looking forward to submitting a planning application for the revised scheme early next year.

Meantime, we were delighted to see the recent news that Orbex (the appointed operators of the Sutherland Spaceport) has been awarded £3.3m in funding from the UK Space Agency as part of the European Space Agency’s ‘Boost’ initiative to further the development of world-leading space launch technologies. This will now be used to develop the Sutherland Spaceport’s Ultra-Green Launch Complex, and we are looking forward to seeing this take shape.

Housing statistics quarterly update – this month, the Scottish Government published its latest housing statistics, providing figures on new housebuilding by public, private and social sectors, and also the Affordable Housing Supply Programme. These show that there was a total of 21,952 new houses completed in Scotland in the year ending in September 2023, representing a decrease of 6% (1,355 homes) on the 23,307 completions in the previous year. At the same time, there has also been a significant drop in the number of new homes on which construction started in this time, with this having fallen by 24% (5,260 homes) from 21,534 starts in the year ending September 2022, to 16,274 starts in the year ending September 2023, with the greatest decrease being in the construction of affordable housing. In the face of significant demand for new homes, this is clearly a cause of some concern, and more needs to be done, including through the planning system, to ensure housing needs are met.

The sky’s the limit – reflecting the pressure for new housing throughout the UK, our eyes were caught by the news earlier this month that a plot of “airspace” was being offered for sale at auction, billed as a potential residential development opportunity. Located directly above two existing flats and a ground floor restaurant/café, the plot does not currently have planning permission, but the sale listing states that the landlord’s consent to develop on top of the roof of the flat below would be provided. Could this be the start of a new trend for building up rather than out, and creating more compact cities, made up of more affordable housing? Or is this pie in the sky thinking? We’ll be watching with interest…

On us – we can’t believe it has already been almost a year since we decided to focus on our core sectors of renewable energy infrastructure and emerging technology related developments, and other projects that deliver community and social benefits. Overall, this has been a very positive decision, and we have had the pleasure of working on some great projects over this time. So, we’d like to say thank you to everyone we have worked with over the year, and here’s to 2024!

In particularly exciting news for us, we’re delighted to report that our Director, Pippa, has become a Chartered Member of the Royal Town Planning Institute!

We’re now looking forward to having a short break over the holiday period and coming back with renewed energy in the new year. Meantime, to find out how we can help with any renewable energy infrastructure or emerging technology related developments, or if you are a charity or community group looking for assistance, then please visit our website or email us at Or, if you would like to sign up for email updates, please click here.

Thanks for reading, merry Christmas, and a happy new year when it comes!

Pippa and Maggie



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