Windfarm development on protected peatland

Peatlands are carbon-rich freshwater wetlands (PDF) which occupy 3% of the global land surface and 12% of UK land area. They among the most carbon-rich ecosystems on Earth, acting as a natural ‘sink’ or store of carbon. Healthy peatlands have a net cooling effect on climate, reduce flood risk and support biodiversity.

The UK Centre for Ecology and Hydrology (UKCEH), an independent research institute, has published a Peatland factsheet (PDF). This explains how peatlands provide important nesting and feeding grounds for many wading birds, as well as important habitats for rare insects and plants. It also explains how peatlands act as a very significant store of carbon:

Healthy peatlands capture CO2 from the atmosphere through photosynthesis. Because the plants that grow on peatlands do not fully decompose under wet conditions, they do not release carbon which would otherwise be returned to the atmosphere as CO2. Peatlands store vast quantities of carbon – ‘locking in’ an estimated 3.2 billion tonnes in the UK alone, and where peat continues to form this helps to offset the effects of human activities (such as fossil fuel burning) that are raising CO2 levels in the atmosphere, leading to climate change. However, overall, peatlands in the UK and around the world are estimated to be a net source of greenhouse gas emissions to the atmosphere, as opposed to a net sink, due to the way they have been managed now and in the past.

Peatland degradation results in the release of this stored carbon. Degradation of peatlands is the results of a range of activities that drain and dry, or remove peat. These include draining for agricultural purposes, peat cutting and extraction, and construction on peatlands.

In December 2025 the Department for Environment, Food and Rural Affairs (Defra) published an updated Environmental Improvement Plan which included a commitment to “restore approximately 280,000 hectares of peatland in England by 2050”. The Scottish Government published its Peatland ACTION five year partnership plan 2025 – 2030 in December 2025.

Many planning applications for construction of windfarms reference the importance of avoiding peat excavation, in particular deep peat areas which hold the greatest volume of stored carbon. A parliamentary petition called for the government to ban windfarms on protected peatland in England, raising concerns about their biodiversity and climate imapcts. The government did not support this. Its response in June 2025 stated:

We will not ban windfarms on peatland in England. Protections in the planning system and best practice guidance ensure development on peatland is carefully considered, mitigated, and compensated. […] As a low carbon emitting technology, onshore wind is a crucial part of the Government’s plans to mitigate against the devastating impacts of climate change.

Energy Security and Net Zero Committee report

The issue of building renewable energy infrastructure on peatland was examined by the House of Commons Energy Security and Net Zero Select Committee as part of its report ‘Gridlock or growth? Avoiding energy planning chaos’, published 7 July 2025.

The report set out concerns about the lack of tools to properly assess the impacts of proposals to construct windfarms on peatland and the lack of detailed guidance for planners and developers (within the then draft National Policy Statement for renewable energy infrastructure, EN-3). It also included conclusions and recommendations for the proposed EN-3:

Building renewable energy infrastructure on peatland is counterproductive to the achievement of net zero if this results in the release of accumulated carbon stores into the atmosphere. Given this context, and the Climate Change Committee’s recommendations for peatland restoration in the Seventh Carbon Budget, it is surprising that the Government’s proposed new guidance for onshore wind in EN-3 does not contain a presumption against building on deep peat, though we recognise that there are areas in which such development would be unavoidable. The weakness in the guidance also appears to undermine efforts of the Department for Environment, Food and Rural Affairs to protect peatland.

Recommendation

The Government should amend the proposed new guidance on onshore wind in EN-3 to:

• whilst recognising there are areas in which development on peat would be unavoidable, introduce a presumption against building onshore wind developments on deep peat; and
• require the downstream carbon emissions from building onshore wind on peatland to be reported in any environmental statement for this kind of development.

Recommendation

The Government should consider publishing an equivalent to Nature Scot’s 2023 guidance, “Advising on peatland, carbon-rich soils and priority peatland habitats in development management”.

The government response to the committee's report published in November 2025 stated that regarding peatland, the Government noted that onshore wind farm sites within England may be proposed on peatland, but developers should seek and rule out other locations before doing so. It would not introduce a presumption against development on deep peat but said it would review carbon assessment tools and consider whether additional guidance, similar to NatureScot’s, should be published for England.

Government also stated that there are wider protections set out in EN-1 the Overarching National Policy Statement for Energy [PDF] regarding irreplaceable peatland habitats such as blanket bog and lowland fens.

Planning for onshore windfarms

The Commons Library published a briefing on Planning for onshore windfarms in May 2024. The briefing covers planning policy for onshore windfarm developments in the UK, applicable at the time of publication. It also details onshore wind statistics between 2010 and 2023, and the community benefits of onshore windfarms. Since the Library publication, the government set a new policy position for England in its 'Policy statement on onshore wind' (July 2024). The policy removed stringent tests for onshore windfarms by revoking parts of the National Planning Policy Framework (NPPF, December 2023). It also introduced large onshore proposals back into the Nationally Significant Infrastructure Projects (NSIP) regime.

Onshore windfarms above and below 100MW

Planning for onshore windfarms is managed under two planning regimes, the Town and Country Planning Act and the Planning Act 2008 (which governs the NSIP regime). In England, large onshore windfarms were introduced back into the NSIP regime in The Infrastructure Planning (Onshore Wind and Solar Generating Stations) Order 2025. The two planning regimes apply as follows:

• Under the Town and Country Planning Act, planning applications for onshore windfarms under 100MW are determined by local planning authorities with decision-making informed by local plan policies and policies in theNPPF (December 2024). Policies for renewable energy projects are covered in Chapter 14: Meeting the challenge of climate change, flooding and coastal change.
• Applications for onshore windfarms over 100MW are determined under the NSIP regime by the Secretary of State, with decision-making informed bynational policy statements (NSP). The statements 'EN-1 Overarching NPS for energy' and 'EN-3 NPS for renewable energy infrastructure' set policies relevant for onshore windfarms.

National Policy Statement for renewable energy infrastructure, EN-3

The National Policy Statement for Renewable Energy Infrastructure (EN-3) was published in December 2025. EN-3 provides the policy framework and assessment principles for determining applications for nationally significant renewable energy projects in England and Wales. It sets out the government’s need case for renewable energy, guidance on site selection, environmental considerations, and how impacts should be mitigated. It summarised the importance of peatland as follows:

Peatlands are sensitive habitats that are important for many species of flora and fauna. Peatlands also provide important water environment benefits and climate adaptation opportunities. Peatlands have soil which is rich in carbon and can extend to several metres in depth. Soil disturbance including compaction, removal and alterations in the profile may lead to changes in the local hydrological regime that can negatively affect biodiversity and the water environment. Soil disturbance can also lead to negative climate impacts including the release of CO2.

The document references peatland a number of times and includes the following guidance when considering windfarms and peat:

Onshore wind farm sites within England may be proposed on peatland, however applicants should rule out other locations before siting developments on peatland. In particular, areas of deep peat, which have the highest potential for carbon emissions, should be avoided.

The England Peat Map is a tool that can be used to identify if a potential site is on peatland, however this should be used alongside other assessments. Where developments are proposed on peatlands, including on deep peat, applicants must conduct a detailed peat survey and must provide justification of the need for infrastructure to be sited on peatland. Where appropriate, applicants should also conduct a geotechnical survey to assess the risk of landslide.

EN3 also points developers to NatureScot’s 2023 guidance, and says the government will publish its own guidance regarding windfarm construction on peatland. It said “applicants should ensure that their applications are consistent with this guidance once it has been published or endorsed by Government” but did not propose a date for publication.

Wales, Northern Ireland and Scotland

Since 2024, Wales and Northern Ireland have seen policy reforms for onshore windfarms:

• In Wales,the focus has been on streamlining the planning and consenting process under the Infrastructure Wales Act 2024. The existing NSIP regime (Planning Act 2008) for onshore windfarms also applies to Wales.
• In Northern Ireland,the Strategic Planning Policy Statement (SPPS) Edition 2 (December 2025) has introduced greater flexibility for wind farm separation distances, policies for re-powering of existing sites and enabling development of emerging, larger scale technologies.

There have been no major changes to the Scottish regime for onshore windfarms.

Stakeholder views

The Yorkshire Wildlife Trust, which is campaigning against the proposals for a 34 (originally 41) wind turbine Calderdale Energy Park, has set out some of the concerns regarding the imapcts of sitting wind farms on deep peat sites:

An important facet of peatland ecosystems is hydrology, the way that water moves and settles within the peat. The bases of 41 turbines, together with the battery station and the tracks required for installation and maintenance of this development will massively disrupt the hydrology of the site. That disruption occurs not just during installation and decommissioning but the entire time the windfarm is running. This will lower the level of the water within the moor relative to the moor’s surface (the water table), drying out millennia of peat.

The layer of plants growing over the peat’s surface protects it from erosion by the weather. When the peatland dries out, that will kill off the plants on its surface, exposing the peat to erosion by wind and rain. This will lead to the formation of deep channels (known as gullies), and steep faces of bare peat (hags), driving the formation of areas of bare peat that lead into a vicious cycle of further erosion. Furthermore, disruption to the moor’s hydrology may lead to contamination of nearby reservoirs and has the potential to aggravate flooding in the settlements below.

The Moorland Association has raised concerns about the biodiversity impacts of poorly sited windfarms:

We are fully supportive of renewable energy solutions, and wind power is an important component of the UK’s energy mix, but it is important to fully understand the biodiversity impacts of these developments. We believe that wind power can coexist with successful local bird populations when turbines are well designed and carefully sited.

However, turbines located inappropriately, especially on sensitive moorlands can cause significant habitat displacement for ground-nesting birds and potential collision risks for raptors.

Scottish Renewables, which represents the renewable sector in Scotland has set out its view on building on peatlands stating that wind farms and peatland can coexist:

There are numerous examples where windfarms have been constructed sensitively in areas where peat is present […]. These projects have demonstrated habitat restoration; good practice in peat reinstatement and construction techniques; use of ‘floating roads’; rapid carbon payback rates; peat slide risk assessments; hydrology studies and minimisation of effects on Ground Water Dependent Terrestrial Ecosystems and; in some cases through planning conditions, significant investment in improvement of the surrounding peatland.Peatland is not of uniform depth and can be highly variable. Responsible wind farm and other renewable technology developers normally seek out the shallowest areas and rocky outcrops to locate infrastructure to avoid disturbing significant areas of peat depth as much as possible.