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Raising the onshore electricity consenting threshold in Scotland: The impact on developers

Scott Davidson, Planning Director, outlines the context behind increasing the onshore electricity consenting threshold in Scotland and the impact of transferring more responsibility to local planning authorities.

The scale and generation capacity of onshore wind turbines has soared in the last twenty years. With Scotland leading the way in onshore wind deployment and support across the UK, the Scottish Government is holding a consultation and inviting views by 27 March 2026 on increasing the onshore electricity consenting threshold.

Raising the onshore electricity consenting threshold

Planning applications for onshore electricity generating stations with a capacity of over 50 megawatts (MW) are currently decided by Scottish Ministers through the Energy Consents Unit (ECU) under powers contained in the Electricity Act 1989.

The Scottish Government is seeking views on increasing the 50MW threshold to 100-150MW to align with UK government plans which would move decision-making from national ECU to local planning authorities.

Applications made under the Electricity Act 1989 to Scottish Ministers cover technologies including onshore wind, solar photovoltaics, Battery Energy Storage Systems (BESS), Pumped Storage Hydro (PSH), hydropower, bioenergy and Energy from Waste.

The context to increase the threshold

Put simply – technology has advanced. Where wind farm applications twenty years ago included turbines of 111.5m in height and a generation capacity of 2-3MW each, we’re now seeing proposals for turbines higher than 180m and with a generation capacity of 5-7MW each^[i]. The overall electricity generation capacity is higher, so it’s necessary to review the current parameters.

At its core, the consultation centres around centralised versus localised consenting for energy projects. Some developers value the strategic oversight of centralised decision-making by Scottish Ministers. As it stands, procedures under the Electricity Act are considered well-established and understood. But transferring responsibility to local planning authorities will increase local decision-making and allow more energy developments to be handled by local planning authorities.

The impact of the proposed changes

Locally aligned decisions – Projects within the 50-150MW range are more likely to be decided by local planning authorities, opening the door for locally aligned decisions.

Potential inconsistency across planning authorities – If there is more local accountability for consenting energy projects, this can lead to inconsistent decisions across planning authorities and potentially prompt more appeals. This unpredictability can create uncertainty for developers and may slow development of necessary electricity generation projects.

Developers will need earlier, deeper multi-agency engagement – The Scottish Government is looking to reform the Electricity Act 1989, introducing a statutory requirement for pre-application engagement with any communities affected by the proposed development. Developers would have to evidence that they have considered community comments and Scottish Ministers could refuse applications that fail to do so.

Transitional complexity for currently submitted projects – The uncertainty of projects under consideration by the ECU falling within the new threshold will need to be clear.

Capacity and skills gaps – For complex energy projects, there may be capacity or skills gaps within local planning authorities, as well as a risk of poorer outcomes in under-resourced areas.

To prevent these risks from becoming reality, there needs to be assurance around local authority capacity, clear national guidance, transitional rules to protect existing applications and fee reform to reflect complexity.

You can share your views before 27 March 2026.

^{[i] Onshore electricity generation - Electricity Act threshold: consultation - gov.scot}