---
title: "Peat management plan: contents and reviewer checks | Vireo"
description: What a peat management plan must contain, the excavation and reuse figures a reviewer tests, and the survey evidence each figure rests on. With sources.
image: https://www.vireonature.com/hubfs/og2_a01.jpg
---

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# Peat management plan: what it must contain and what a reviewer checks

For EIA coordinators and consents managers preparing a wind farm or grid application on peat in Scotland

A peat management plan in Scotland shows how the layout avoids peat, how much peat is still excavated and where each cubic metre goes. NatureScot and SEPA both ask for a volume against every use, and every volume rests on the peat depth survey.

By the Vireo teamPublished 10 November 202612 minute readSources checked 10 November 2026

![Peat management plan: contents and reviewer checks | Vireo](https://www.vireonature.com/hs-fs/hubfs/ins_01.jpg?width=1200&height=630&name=ins_01.jpg)

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Key points

- NatureScot guidance, revised in March 2026, asks for "A table detailing the infrastructure and associated average peat depths, estimated volumes excavated and re-used".
- Plans for operational Scottish wind farms anticipate an average of 8,060 cubic metres of excavated peat per turbine, in a ClimateXChange study completed in January 2025.
- The Scottish Government page for the 2012 peat volumes guidance says the document "has not been reviewed or updated since".

Your peat management plan exists because of one sentence in [National Planning Framework 4](https://www.gov.scot/publications/national-planning-framework-4/pages/3/), published on 13 February 2023. Policy 5 says: "A peat management plan will be required to demonstrate that this approach has been followed". This guide sets out what the plan holds, which figures a reviewer tests and where each figure comes from.

**8,060 cubic metres**

Against

Average peat excavation anticipated per turbine, plans of operational Scottish wind farms

Source

ClimateXChange, Reuse of excavated peat on wind farm development sites

Date

Checked 10 Nov 2026

**About 1 m**

Against

Depth below which SEPA finds very few uses for excavated peat

Source

SEPA, WST-G-052, May 2017

Date

Checked 10 Nov 2026

**2012**

Against

Year the peat volumes guidance dates from, not reviewed since

Source

Scottish Government publication page

Date

Checked 10 Nov 2026

## What the plan has to demonstrate

A peat management plan is the document that shows how a development avoids peat, how much it still excavates and where that peat goes. "This approach" in Policy 5 is a specific sequence.

Policy 5(d) requires a site-specific assessment of "the baseline depth, habitat condition, quality and stability of carbon rich soils". The policy says the assessment should ensure "that adverse impacts are first avoided and then minimised through best practice".

So the plan is a proof of design, with volumes attached. A plan that only describes handling methods answers a different question.

Policy 5 applies to "Development proposals on peatland, carbon-rich soils and priority peatland habitat". It names essential infrastructure and renewable energy generation among the cases it supports.

## Which documents does a reviewer hold the plan against?

Six public documents frame the review. Policy sets the duty, agency guidance sets the content, and survey guidance sets the evidence.

| Document | Publisher and date | What it gives the plan |
| --- | --- | --- |
| [National Planning Framework 4](https://www.gov.scot/publications/national-planning-framework-4/pages/3/), Policy 5 | Scottish Government, 13 February 2023 | The duty to submit a plan, and the avoid then minimise test |
| [Advising on peatland habitats and carbon-rich soils in development management](https://www.nature.scot/site-visit-template-assessment-peatland-proposed-development-sites) | NatureScot, June 2023, revised March 2026 | What a plan or outline plan should include |
| [Developments on Peat and Off-Site Uses of Waste Peat](https://www.sepa.org.uk/media/287064/wst-g-052-developments-on-peat-and-off-site-uses-of-waste-peat.pdf) (WST-G-052) | SEPA, issued May 2017 | The hierarchy for excavated peat, and when it becomes waste |
| [Guidance on the assessment of peat volumes, reuse of excavated peat, and the minimisation of waste](https://www.gov.scot/publications/assessment-of-peat-volumes-reuse-of-excavated-peat-and-minimisation-of-waste-guidance/) | Scottish Government page dated 16 July 2014; document dates from 2012 | Volume and reuse method, kept for reference |
| [Peatland Survey: Guidance on Developments on Peatland](https://www.gov.scot/binaries/content/documents/govscot/publications/advice-and-guidance/2018/12/peatland-survey-guidance/documents/peatland-survey-guidance-2017/peatland-survey-guidance-2017/govscot:document) | Scottish Government, Scottish Natural Heritage and SEPA, 2017 | The probing survey behind every depth |
| [Peat landslide hazard best practice guide](https://www.gov.scot/publications/peat-landslide-hazard-risk-assessments-best-practice-guide-proposed-electricity/), second edition | Scottish Government, 26 April 2017 | Stability checks on excavation and storage |

Sources: the six documents named, each opened on 10 November 2026. Dates are those shown by the publisher.

One caution on the volumes guidance. Its [Scottish Government publication page](https://www.gov.scot/publications/assessment-of-peat-volumes-reuse-of-excavated-peat-and-minimisation-of-waste-guidance/) states: "This document, which dates from 2012, has not been reviewed or updated since." The page adds that it "does not reflect current legislation, good practice or controls".

Cite it for method if you use it. Take current content requirements from the 2026 NatureScot guidance. This guide quotes the SEPA text issued in May 2017 and no later one. Check the SEPA website for the current version before you cite it.

## What a peat management plan must contain

NatureScot sets the content in one paragraph of Annex 2 of its [development management guidance](https://www.nature.scot/site-visit-template-assessment-peatland-proposed-development-sites). A plan, or outline plan, "should include detail on the extent of peat within the proposal", with the impacts and the mitigation adopted.

The same paragraph lists the rest:

- A table of each infrastructure element with its average peat depth, the estimated volume excavated and the volume reused.
- Temporary storage: where peat is stored, and "the habitat type and condition of the area on which they will be stored".
- How stored peat degrades over time, "with steps taken to ensure the peat remains in a reusable condition".
- The purpose of each reuse: "reinstatement, restoration, on-site offsetting, off-site offsetting or enhancement".

[SEPA guidance WST-G-052](https://www.sepa.org.uk/media/287064/wst-g-052-developments-on-peat-and-off-site-uses-of-waste-peat.pdf) (May 2017) adds a requirement for peat that leaves the site. It expects off-site uses "to be identified in the peat management plan, including estimated volumes for each use, destination, final intended outcome and justification of suitability".

An outline plan is normal at application. NatureScot notes that "outline HMPs, PMPs and CEMPs will be produced at application stage" and should be "sufficiently detailed to allow assessments to be carried out". HMP is the habitat management plan, PMP the peat management plan and CEMP the construction environmental management plan.

NatureScot also says avoidance and minimisation are often demonstrated in the siting and design rationale. So show the layout options you rejected and the peat each one would have excavated.

## The excavation and reuse figures a reviewer tests

A reviewer tests whether each cubic metre excavated has a genuine use. SEPA sets the order of preference in WST-G-052 (May 2017), and the order starts with not digging.

STEP 1PreventMinimise excavationand disturbanceSTEP 2Use the peatOn site, or off siteto restore peatlandSTEP 3Recycle or recoverRegulated as a wasteactivity in the 2017 textSTEP 4DisposeOnly after all otheroptions are discounted

Figure 1. The SEPA hierarchy of management options for excavated peat, in order of preference. Source: SEPA, Developments on Peat and Off-Site Uses of Waste Peat (WST-G-052), May 2017.

Four tests follow from the 2017 text.

- **Need.** SEPA asks for "evidence that the quantity to be used matches, not exceeds, the requirement for the proposed use".
- **Excess.** "Use of unsuitable material and/or excessive quantities (i.e. more than needed) will be regarded as disposal".
- **Depth.** SEPA finds "very few opportunities to use catotelmic peat (generally peat below approximately 1m depth)". Catotelmic peat is the wet lower layer, about 90 per cent water.
- **Time.** In the 2017 text, waste peat stored for more than three years before treatment or recovery, or more than one year before disposal, "is likely to constitute a landfill".

NatureScot applies a further test to the purpose of each reuse. It warns that "there is little evidence of the successful use of excavated peat in peatland restoration". Of peat used on site as backfill, it says "it cannot be considered as offsetting or enhancement".

Published research points to the weak spots. The [ClimateXChange study Reuse of excavated peat on wind farm development sites](https://www.climatexchange.org.uk/?p=10099), completed in January 2025, reviewed plans for operational Scottish wind farms. They anticipated an average of 8,060 cubic metres of peat per turbine (plus or minus 1,464). The average per wind farm was 328,446 cubic metres (plus or minus 59,650).

The same study "found that more peat is often excavated than planned". It also describes plans where "it is assumed that all excavated material will be peat". In those plans, "differences between peat layers (acrotelm and catotelm) are not distinguished". The acrotelm is the fibrous upper layer.

A plan that splits volumes by layer and states its depth method answers those findings before anyone raises them.

## What survey evidence does each figure rest on?

Every volume in the table is an area multiplied by a depth, and the depth comes from the probing survey. The [Peatland Survey guidance](https://www.gov.scot/binaries/content/documents/govscot/publications/advice-and-guidance/2018/12/peatland-survey-guidance/documents/peatland-survey-guidance-2017/peatland-survey-guidance-2017/govscot:document) of 2017 lists among its outputs the "Volume of excavated peat to inform the Peat Management Plan".

It also asks for "Detail on the method used to calculate the depth and volume of peat that will be excavated at different locations". Where you interpolate between probes, the map "should include location and depth of surveyed points as an overlay".

The detailed survey uses "a 10m by 10m grid basis around the centre of each proposed turbine base". Our guide to [what Scottish peat survey guidance asks for](https://www.vireonature.com/insights/peat-survey-guidance-scotland) covers the spacings and records in full.

The same depths feed two other documents, so all three must agree.

- **Carbon calculator.** The survey guidance asks for "Average peat depth and maximum peat as required in the Carbon Calculator assessment". The [carbon calculator factsheet](https://www.gov.scot/publications/carbon-calculator-for-wind-farms-on-scottish-peatlands-factsheet/), updated on 26 June 2026, states that "the online carbon calculator hosted by SEPA is no longer in use". It directs applicants to the Energy Consents Unit for an offline version.
- **Peat landslide assessment.** The [best practice guide](https://gov.scot/publications/peat-landslide-hazard-risk-assessments-best-practice-guide-proposed-electricity/pages/4) lists, under ground investigation, "quantifying the amount of peat that may be excavated as compared with the amount that may be reused". It also says "the loading of peat slopes by plant or by temporary peat storage areas at the slope crest should be avoided".

ClimateXChange reports "some ambiguity related to total peat volumes until excavation has started". So state the range on your totals, and say how many probes sit under each element.

## Illustrative example

This is an invented eight-turbine wind farm on blanket bog, with no real names or locations. The plan lists four infrastructure elements. Each area comes from the layout drawing and each average depth from the detailed probing.

| Element | Area (square metres) | Average peat depth (m) | Excavated volume (cubic metres) |
| --- | --- | --- | --- |
| Turbine bases and hardstandings (8 at 2,500 square metres) | 20,000 | 1.2 | 24,000 |
| Excavated track (4,000 m by 6 m) | 24,000 | 0.8 | 19,200 |
| Substation and compound | 6,000 | 0.6 | 3,600 |
| Borrow pit | 10,000 | 0.4 | 4,000 |
| **Total** | 60,000 |  | **50,800** |

Illustrative figures, not from a real site. Volume is area multiplied by average depth, set out as the table NatureScot guidance (revised March 2026) asks for.

Planned reuse is 37,000 cubic metres. That is 20,000 to reinstate the borrow pit, 14,000 on track and hardstanding edges, and 3,000 to reinstate the temporary compound. Excavation less reuse leaves 13,800 cubic metres with no stated use.

Turbine bases, hardstandings24,000Excavated track19,200Substation and compound3,600Borrow pit4,000Planned reuse, all uses37,000No stated use13,800Cubic metres of peat, as measured in the ground

Figure 2. Excavated volume by element, planned reuse and the balance for the illustrative site. Vireo arithmetic: area multiplied by average peat depth. Illustrative figures, not from a real site.

Three checks follow. The 13,800 cubic metres needs a use, a redesign or a route further down the SEPA hierarchy. At the turbine bases, an average depth of 1.2 m puts peat below the 1 m mark where SEPA finds few uses. And the total is 6,350 cubic metres per turbine, against the 8,060 average in the ClimateXChange review.

Now move one input. If detailed probing puts the turbine average at 1.5 m, that element rises to 30,000 cubic metres. The balance with no stated use becomes 19,800 cubic metres, with the layout unchanged.

Try it

### Excavation and reuse balance

Enter up to four infrastructure elements and your planned reuse. The tool multiplies each area by its average peat depth, as in the table NatureScot asks for, and compares the total with reuse. Depths come from your probing survey.

Element 1

Name

Area (square metres)

Average peat depth (m)

Element 2

Name

Area (square metres)

Average peat depth (m)

Element 3

Name

Area (square metres)

Average peat depth (m)

Element 4

Name

Area (square metres)

Average peat depth (m)

Planned reuse, all uses (cubic metres)

Reset to the example

Arithmetic only: area multiplied by average peat depth, summed, less planned reuse. Depths come from your probing survey, and volumes are as measured in the ground. Leave an element blank to skip it. Nothing you enter leaves this page.

[Send us your site with these numbers](https://www.vireonature.com/pre-survey-pack)

You have a layout to fix and the detailed probing is still to come. [Send us your site](https://www.vireonature.com/pre-survey-pack) and we reply within two working days.

## Is your plan ready for a reviewer?

A plan is ready when each item below is written down and traceable to the survey data. The list follows the NatureScot, SEPA and Scottish Government guidance cited above.

### Reviewer's checklist for a peat management plan

Tick what is already in place and written down.

The extent of peat across the whole site, mapped from the survey A siting and design rationale showing how the layout avoids the deeper peat A table of each infrastructure element with area, average peat depth, excavated volume and reused volume The method used to calculate depth and volume, with probe points shown on any interpolated map Volumes split between the upper (acrotelm) and lower (catotelm) layers A stated need and quantity for each reuse, and its purpose: reinstatement, restoration, offsetting or enhancement Temporary storage locations, the habitat they sit on, and steps to keep stored peat reusable Storage kept away from slope crests, consistent with the peat landslide assessment Any off-site use with its volume, destination, intended outcome and justification, and SEPA consulted The same depths and volumes in the carbon calculator inputs and the landslide assessment

## What to do next

- Run your own figures through the balance above and note the gap.
- Check your draft against the NatureScot paragraph line by line, then against the SEPA hierarchy.
- Ask your surveyor for the probe count under each element and the range on each average depth.
- Settle where the deep peat is likely to sit before the layout is fixed. The [Site Evidence Pack](https://www.vireonature.com/pre-survey-pack) is a desk read of a site before survey, and every figure in it carries its range, its source and its test label.

A pack gives a desk read of likely peat depth and condition for the site, and it tells the surveyor where to probe first. Tested results are on the [Results page](https://www.vireonature.com/results). Vireo can also supply the surveys: drone, aerial and ground, including ground-penetrating radar and magnetometry. Coverage is the UK and Ireland.

## Frequently asked questions

Does an overhead line or substation need a peat management plan?

Policy 5 of National Planning Framework 4 applies to "Development proposals on peatland, carbon-rich soils and priority peatland habitat". The peat landslide guide, written for generation projects, adds that "the principles apply equally to S37 applications for above-ground overhead lines".

Is excavated peat waste?

SEPA guidance WST-G-052 (May 2017) states: "Excavated peat will be waste if it is discarded or the holder intends to or is required to discard it." It asks developers to "prioritise the use of excavated peat on-site in the first instance".

## Sources

1. [Scottish Government: National Planning Framework 4, Policy 5 Soils (13 February 2023) (checked 10 November 2026)](https://www.gov.scot/publications/national-planning-framework-4/pages/3/)
2. [NatureScot: Advising on peatland habitats and carbon-rich soils in development management (June 2023, revised March 2026) (checked 10 November 2026)](https://www.nature.scot/site-visit-template-assessment-peatland-proposed-development-sites)
3. [SEPA: Developments on Peat and Off-Site Uses of Waste Peat, WST-G-052, version 1 (May 2017) (checked 10 November 2026)](https://www.sepa.org.uk/media/287064/wst-g-052-developments-on-peat-and-off-site-uses-of-waste-peat.pdf)
4. [Scottish Government: Assessment of peat volumes, reuse of excavated peat and minimisation of waste: guidance, publication page (16 July 2014; document dates from 2012) (checked 10 November 2026)](https://www.gov.scot/publications/assessment-of-peat-volumes-reuse-of-excavated-peat-and-minimisation-of-waste-guidance/)
5. [Scottish Government, Scottish Natural Heritage and SEPA: Peatland Survey. Guidance on Developments on Peatland (2017) (checked 10 November 2026)](https://www.gov.scot/binaries/content/documents/govscot/publications/advice-and-guidance/2018/12/peatland-survey-guidance/documents/peatland-survey-guidance-2017/peatland-survey-guidance-2017/govscot:document)
6. [Scottish Government: Proposed electricity generation developments, peat landslide hazard best practice guide, second edition (26 April 2017) (checked 10 November 2026)](https://www.gov.scot/publications/peat-landslide-hazard-risk-assessments-best-practice-guide-proposed-electricity/)
7. [Scottish Government: Peat landslide hazard best practice guide, second edition, section 4, Detailed site assessment (26 April 2017) (checked 10 November 2026)](https://gov.scot/publications/peat-landslide-hazard-risk-assessments-best-practice-guide-proposed-electricity/pages/4)
8. [ClimateXChange: Reuse of excavated peat on wind farm development sites (research completed January 2025) (checked 10 November 2026)](https://www.climatexchange.org.uk/?p=10099)
9. [Scottish Government: Carbon calculator for wind farms on Scottish peatlands: factsheet (20 November 2018, updated 26 June 2026) (checked 10 November 2026)](https://www.gov.scot/publications/carbon-calculator-for-wind-farms-on-scottish-peatlands-factsheet/)

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## Keep reading

### [![How accurate is the England Peat Map? What national peat maps support at site scale](https://www.vireonature.com/hs-fs/hubfs/ins_05.jpg?width=1200&height=630&name=ins_05.jpg) Guide10 Nov 2026 · 13 minute read How accurate is the England Peat Map? What national peat maps support at site scale What the England Peat Map and other national peat maps are designed to support, how map depth compares with probed depth, and what a site decision needs. Read →](https://www.vireonature.com/insights/england-peat-map-accuracy)

### [![The peat depth gap: where the open measurements are](https://www.vireonature.com/hs-fs/hubfs/ins_13.jpg?width=1200&height=630&name=ins_13.jpg) Guide10 Nov 2026 · 10 minute read The peat depth gap: where the open measurements are 82 per cent of mapped peat across Britain and Ireland lies more than 1 km from any openly published peat depth measurement. Look up your area. Read →](https://www.vireonature.com/insights/peat-depth-gap)

### [![Peat surveys for wind farms and grid lines in Scotland: what the guidance asks for](https://www.vireonature.com/hs-fs/hubfs/ins_peat.jpg?width=1200&height=630&name=ins_peat.jpg) Guide10 Nov 2026 · 8 minute read Peat surveys for wind farms and grid lines in Scotland: what the guidance asks for The two survey phases, probe spacings, records and outputs Scottish guidance expects on peat before a layout is fixed, and where a desk read saves fieldwork. Read →](https://www.vireonature.com/insights/peat-survey-guidance-scotland)

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## Related guides and services

- [Wind farm and grid evidence →](https://www.vireonature.com/solutions/wind-and-grid)
- [Plan a peat depth survey: Site Evidence Pack, £3,600 →](https://www.vireonature.com/pre-survey-pack)
- [Peat survey guidance for wind farms in Scotland →](https://www.vireonature.com/insights/peat-survey-guidance-scotland)
- [Peat landslide risk assessment guide →](https://www.vireonature.com/insights/peat-landslide-risk-assessment-scotland)

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