View the full draft of NPPG6 from the Scottish Executive website.

The following suggestions in response to the above consultation are from the Mountaineering Council of Scotland (MCofS), the official organisation that represents hillwalkers and mountaineers both individually and through clubs.

The MCofS welcomes the opportunity to comment on this subject as we believe that renewable sources provide the only truly sustainable means of producing the nations energy in the longer term. Despite this recognition of the value and logic of renewable energy, the MCofS is very concerned about the landscape and environmental damage that can be caused by the more inappropriate renewable energy developments that are proposed from time to time. Through this consultation response we hope to give our view as to where the balance should lie between encouraging renewable energy development and the protection of environmentally important areas and sites.

Our overall view of the draft NPPG is that it seeks to promote renewable energy without placing sufficient emphasis on the protection of landscape and other negative impacts that some renewable energy developments can have. Without the balancing effect of sufficiently robust environmental protection measures, we believe there could be a series of controversial planning cases that could damage the image and public perception of renewable energy.

If renewable energy is to be widely accepted and supported by the people of Scotland it is important that it is not seen as being environmentally damaging. Certain proposed developments in recent years have been controversial and have caused damage to the image of renewable energy. The planning system should be sufficiently robust in order to prevent these schemes going ahead. If the contentious schemes are given an easy passage through the planning system this will lead to unfavourable publicity and set the industry back.

The case of the proposed Shieldaig hydro scheme is a good example of renewable energy gaining a bad name because of the actions of a determined developer attempting to develop a scheme in an inappropriate area. This proposed scheme has threatened one of Scotland's finest tracts of wild land and in return has offered only a small amount of electricity and no extra employment beyond the construction phase. Despite SNH and Highland Council as statutory consultees opposing the scheme, plus a number of conservation and recreation bodies, including the MCofS, and representatives from the local tourism business community also standing up against the scheme, this proposal was forced through the planning system at considerable public expense. In our view the then Scottish Office should not have awarded this scheme an SRO contract in the first place. An assessment of environmental sensitivity should be part of the initial investigation into SRO bids and obviously contentious applications should be turned down at the outset.

The current situation with the Shieldaig proposal is causing even more damage to the renewables cause. The developer, Highland Light and Power (HLP), has withdrawn its application within weeks, or even days, of the reporter's final report being published. Feeling that it was about to lose its case the company effectively destroyed the evidence. HLP's application caused this inquiry to take place and our estimate is that over £0.5M of public money was spent on the inquiry, taking into account the reporter's time and expenses, plus those of SNH and Highland Council. Despite this public investment, the public are denied the opportunity to see the reporter's assessment of some very complex issues and to gain from the benefit of his wisdom. In our view, Highland Light and Power should be made to pay-back the public money that they caused to be spent or they should face up to having the report published. This may be a comment that goes beyond the scope of a particular NPPG consultation, but if the government is pursuing a policy of promoting renewable energy it should be aware that the actions of companies like HLP are causing a negative public perception of renewable energy.

In NPPG14 (Natural Heritage) paragraph 16 gives recognition to the value of wild land. We believe that there should be the same recognition in other NPPG's including this one on renewable energy. The Scottish countryside provides the basis for the recreation of large numbers of people and this in turn supports the tourism industry which provides employment for a significant proportion of our population, particularly in the rural areas of Scotland. Damage to our countryside can detract from the value of the recreational experience of those resident in Scotland, but it can act as a deterrent on even visiting the country in the case of potential tourists from outwith Scotland.

The case for the tourism industry is not made strongly enough in paragraph 30. Landscape is the raw material for our tourism industry and damage to that resource will harm that industry. Paragraph 30 takes the positive view that wind farms or hydro schemes can become an attraction in their own rights, but fails to present the opposite argument that they can detract from the enjoyment of an area and lead to a loss of repeat visits.

The comment in paragraph 40 about ancillary elements such as access tracks needing to be addressed is woefully inadequate. Bulldozed tracks in the Scottish Highlands are a major issue for the MCofS, because they lie outside the current planning system and we feel they should be brought within the range of planning control. Advising planning authorities to "address them" is inadequate, because it provides them with no powers on which to refuse the application or recommend less damaging alternatives.

We believe that if renewable sources are ever to produce really significant amounts of energy the technology needs to be developed to harness the energy found at sea. The oil industry has gone to extraordinary lengths to bring oil from the sea bed to our homes and workplaces, and in the same way the energy of the wind, waves and tides could be captured far out to sea and the flow of electricity be brought ashore. Exploiting offshore energy has the double advantage of tapping into potentially massive amounts of energy as well as avoiding problems associated with landscape despoliation.

We feel that paragraphs 12 and 13 are overly dismissive of offshore power. The comment in the NPPG may only be reflecting government policy, but if this is the case we would like to see a more positive commitment from government about the future role of offshore power.

Linked to our comments about offshore power, we also believe that the draft NPPG is also overly dismissive of small-scale stand alone projects. In our view these should count towards our national and international targets, because in the rural areas of a country like Scotland with its high wind speeds and steep streams and rivers there is considerable scope for families and businesses generating their own power from renewable sources. Government policy should be encouraging this, whilst at the same time the planning system should be protecting the landscapes and townscapes from overly intrusive stand-alone developments. We feel that this draft NPPG should make more positive comment about this area of renewable energy as well as giving planners more guidance for assessing such facilities.

We are generally supportive of paragraph 22, which recommends the use of brownfield sites for renewable energy developments. We believe that 3 wind turbines on a brownfield site are better than 2 on a mountain.

The amount of energy consumed in building a renewable energy structure needs to be taken into account at its planning stage. This draft NPPG gives the impression that increasing our percentage of energy produced from renewable sources in order to meet our international obligations is of such great importance that it will be conveniently overlooked if the development of a renewables scheme is actually going to require the equivalent of 10 or 20 years of its expected energy output to construct it. The energy to build a hydro scheme or wind farm is mainly going to be derived from fossil fuels, so the logic should require some form of energy audit to determine the level of conventional energy that is going to be used in developing the scheme.

Although it is not a planning matter as such, we would like to see a stronger government commitment to energy conservation. The amount of energy consumed in the UK each year is increasing, and the amount of new renewable energy developed each year is less than the overall annual increase. If we are to really address the issues of climate change and conservation of resources we are going to have to learn to use less energy. The use of energy efficient materials in Scottish homes and offices would be a good starting point.

This NPPG concentrates on the "middle way" of small-scale renewable energy developments, and we believe this area does have a future, but we feel that the real future is to either side in terms of scale. We would like to see more emphasis on truly small-scale stand alone projects, as well as research into large-scale offshore energy production.