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Scottish electricity threshold: 64% favour 150MW

Scottish consultation responses favour raising the 50MW electricity threshold to 150MW, but developers warn local planning teams need specialist capacity.

The Scottish electricity threshold could be raised well beyond its current 50MW level after a government consultation found that 120 of 187 respondents who selected an option favoured 150MW. However, the results also expose a sharp divide between community respondents, developers and planning authorities.

The Scottish Government’s consultation response summary, published on 8th October 2026, records 214 submissions on whether larger onshore electricity-generation projects should be decided by councils rather than Scottish Ministers. Of those who answered the threshold question, approximately 64% selected 150MW.

No threshold has changed. The 50MW dividing line remains in place, and the document summarises consultation responses rather than announcing a government decision or commencement date. If you are following an energy scheme near your home, I would keep those two stages separate: support for changing who decides an application does not change the route for a live proposal.

Scottish electricity threshold: what the consultation found

In Scotland, the Electricity Act 1989 generally places applications for onshore electricity generating stations above 50 megawatts (MW) with Scottish Ministers, through section 36. Applications of 50MW or less are largely determined by local planning authorities under the Town and Country Planning (Scotland) Act 1997. Ministers can grant deemed planning permission alongside section 36 consent.

The Scottish Government consulted between 30th December 2025 and 27th March 2026 on increasing that threshold. The new results publication records 214 responses, of which 194 were submitted online. The Scottish electricity threshold results summarise common themes rather than a government decision accepting any proposal. The central question offered options of 50MW, 100MW and 150MW.

Among the 187 people and organisations who selected an option, 120 chose 150MW, 42 selected the existing 50MW level and 25 favoured 100MW. That is approximately 64%, 22% and 13% respectively. I would read those Scottish electricity threshold figures as the preferences of people answering that question, not all 214 respondents or a representative sample of the wider public.

The Government also notes that some people choosing 150MW actually preferred a higher threshold of 350MW or 500MW, or no threshold at all. The headline 150MW response is therefore partly a vote for a more substantial transfer of responsibility, rather than universal agreement on precisely 150MW.

Communities, developers and councils favour different routes

The strongest support for the 150MW option came from community and individual respondents: 100 of the 127 in that category who answered the threshold question selected it. Their submissions often favoured local knowledge, accountability and giving communities a greater say in decisions about the landscapes and infrastructure around them. The development, property and land management sector told a different story.

Of the 29 respondents in that category who selected a threshold, 20 chose to retain 50MW, four selected 100MW and five selected 150MW. The principal concern was not necessarily opposition to renewable energy, but the capacity and specialist expertise available to local authorities to process larger applications. Planning authorities themselves were divided.

Of the 19 that chose an option, nine selected 150MW, eight selected 100MW and two chose 50MW. Some councils saw the value of more decisions and associated planning fees being handled locally. Others warned that already stretched planning teams could struggle with a major expansion of complex energy work. On a separate question, 148 of 209 respondents supported having a single threshold across technologies.

Yet some respondents supporting that principle still wanted battery energy storage systems (BESS) treated differently. That unresolved distinction matters where a project combines generation and storage, or where different technologies have very different footprints, environmental impacts and technical risks.

Raising the threshold would change who decides, not whether projects are acceptable

If a future Scottish electricity threshold reform moved the section 36 dividing line to 150MW, more electricity-generation proposals would generally pass through planning authorities rather than directly through the ministerial electricity-consenting route. A project that is currently above the 50MW line could fall into the local route if its capacity remained below the new threshold.

That would be a procedural change, not an automatic consent or a relaxation of planning policy. The proposal would still need to be considered against the statutory development plan, including National Planning Framework 4, relevant local development plan policies and other material considerations. Environmental assessment, landscape, ecology, access, grid and other project issues would not disappear.

Neither does today’s document settle how capacity should be measured where a scheme includes storage, overplanting or more than one generating technology. Respondents expressly called for national clarity on those points and on the assessment of cumulative impacts. Because the Scottish electricity threshold has not changed, developers should not now recalculate a project’s consent route on the assumption that a new statutory threshold is already operative.

The results also underline a political and practical trade-off. More local decisions might offer stronger place-based accountability. Equally, a transfer without sufficient technical support could produce inconsistent approaches, longer application timetables and more appeals. Both are concerns recorded in the response summary rather than conclusions the Government has adopted.

Transitional rules may prove as important as the number

One of the sharpest divisions concerns existing applications. The consultation described a future threshold applying to new applications only, but it invited comment on the treatment of schemes already in the system. Many developers and planning authorities supported protecting applications already submitted, and some sought protection for projects at an advanced pre-application stage.

They pointed to the cost of preparing environmental material, consulting stakeholders and planning around an identified decision-maker. Many community and individual respondents instead wanted changes to apply to applications not yet determined. That would potentially bring some established schemes into the locally determined route.

The report records suggestions ranging from a three-month transition to 12-month grace periods, alongside an option for developers to elect a consenting route in certain circumstances. None of these suggestions is adopted policy. A developer with a live section 36 application should therefore continue on the existing legal footing unless and until final legislation and transitional provisions say otherwise.

For schemes still being designed, I would keep programme assumptions under review while the Scottish electricity threshold is considered. Premature restructuring could be expensive, particularly if the final transitional arrangements differ from what an applicant expects.

Planning fees and specialist staffing are the main delivery risks

A higher threshold would not by itself provide more planning officers, environmental specialists or legal capacity. The consultation responses repeatedly raised the resources needed to understand larger renewable schemes, deal with statutory consultees, run community engagement and defend decisions on appeal. The Scottish Government’s summary records calls for sufficient planning fees, resources and specialist/technical support for the authorities inheriting additional work.

Respondents also questioned whether existing fee structures fairly reflect the scale of complex renewable applications and whether specialist support could be shared through the National Planning Hub. For landowners and project developers, this is more than an administrative footnote. The authority handling an application can affect pre-application expectations, consultation procedures, the timetable, the evidence needed and the available appeal route.

A local route that looks simpler on paper may not be quicker if the receiving authority lacks staff and specialist technical advice. There is a direct connection with the Energy Consents Unit’s latest performance report, published on 6th October. Planning Geek reported that 46 wind applications within the Government’s 12-month determination ambition remained undecided at the end of the report period.

That separate evidence highlights the existing pressure on central energy consents, but it does not prove that transferring applications to councils would solve the delay.

What applicants should do while the 50MW threshold remains

The first step is to identify the scheme’s actual statutory consent route using existing law. Where section 36 applies, applicants should account for engagement with the Energy Consents Unit and the possibility of deemed planning permission. Where a project sits in the local planning system, they should check the council’s validation expectations, development plan and environmental requirements.

For schemes approaching the 50MW line, early consideration of generating capacity and any associated BESS element is particularly important. The consultation summary shows why apparently small technical distinctions can create large changes in process. The eventual wording of any reform will matter more than a headline MW figure. Applicants should also build a realistic programme for stakeholder engagement.

A shift of decision-maker does not remove local objections or environmental scrutiny. Planning Geek has separately covered the Scottish Major Projects Office and calls for faster Scottish planning decisions, both of which show that resourcing and coordination are central issues across the system.

What happens next?

The Scottish Government has now published consultation findings, but it has not announced which threshold, if any, Ministers intend to introduce. A formal policy decision, legislation, commencement arrangements and operational guidance would be needed before practitioners could rely on a revised figure.

Today’s publication therefore creates a strong case for tracking the next ministerial response, especially on BESS, hybrid schemes, fee arrangements and the treatment of applications already submitted. It does not create an immediate new entitlement to have a 100MW or 150MW energy proposal decided by a local authority. The practical message is straightforward.

There is significant support among consultation respondents for moving more energy decisions to councils, but support is uneven, and the sector most exposed to preparing large schemes is particularly cautious. The existing 50MW rule remains the one to use today.

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