Draft onshore wind policy statement November 2017: consultation analysis

This report presents an analysis of responses to the consultation on a draft onshore wind policy statement.

Executive Summary


1. The Scottish Government consultation on a draft Onshore Wind Policy Statement was one of a number of consultations published alongside the draft Energy Strategy.

2. The draft Onshore Wind Policy Statement reaffirmed the Scottish Government's existing onshore wind policy and the consultation asked for views on a number of issues relating to supporting the sector. It ran from 24 January until 30 May 2017.

Respondent Profile

3. 89 organisations and individuals, from the following respondent sub groups, submitted a response to the consultation:

Respondent Groups

Aviation specialists 4
Communities 3
Environmental and energy advisory (non-governmental) 6
Public Sector / Delivery Agency / Regulator 7
Land / Landscape 2
Lobby and interest groups 4
Local authorities and planners 16
Onshore wind industry 35
Total organisations 77
Individuals 12
Total respondents 89

Main Findings: Route to Market

4. Many respondents praised the Scottish Government's aim to support a route to market for onshore wind.

5. A large proportion of respondents either explicitly stated, or implied, support for the inclusion of wind farm 'efficiency' as a material consideration in the Section 36 consents guidance. A major theme in responses, from across groups and particularly the onshore wind industry, was that 'efficiency' is either difficult to define or, potentially, ambiguous.

6. Another key theme, from across groups, was that considering the 'efficiency' of new wind farms should not be limited to Section 36 consents guidance but should equally apply to developments considered under the Town and Country Planning (Scotland) Act 1997.

7. A further major theme related to larger turbines, often linked to remarks regarding their relative efficiency. Some respondents commented that they would welcome more explicit encouragement that larger turbines should be used where possible whilst others highlighted concerns regarding landscape and environmental impacts if larger turbines are deployed in the interests of seeking greater efficiency.

8. Respondents commented on the need to better align the objectives and issues within the draft Onshore Wind Policy Statement with planning policy.

9. There was support for transforming the grid, and in particular reformation of the grid charging structure. Some respondents suggested that the Scottish Government might facilitate discussions to assist in easing grid connection infrastructure or incentivising schemes away from a traditional model of supply to the grid i.e. storage. These measures were identified as routes to reducing costs.

10. There was support for the open tender process for any Power Purchase Agreements ( PPA) provider to help support community energy or small-scale projects and also for local energy systems to facilitate local generation, storage and use.

11. Several respondents, notably from the onshore wind industry group, cited the importance of the Scottish Government continuing its lobbying efforts with the UK government to secure long term Contracts for Difference ( CfD) for onshore wind. Other issues particularly highlighted by respondents from the onshore wind industry group related to significant increases in planning application fees and business rates, both of which are felt to adversely affect developers' costs at a time of reduced subsidy.

Main Findings: Repowering

12. 45 respondents agreed with the Scottish Government's approach to repowering while five did not. A key theme was agreement with the Scottish Government's support for the principle of repowering and that repowering will be important to achieving energy targets.

13. Many respondents favoured the commitment that repowered sites should continue to be assessed on their own merits and be sited and designed to minimise environmental impacts and protect residential amenity. In addition, several respondents commented specifically that they welcomed reference to the role for and / or guidance from Scottish Natural Heritage ( SNH).

14. A number of comments and questions relating to planning in connection with repowering were each raised by small numbers of respondents. Some respondents from the local authorities and planners group as well as the onshore wind industry suggested that a review of the main technical and planning issues associated with re-powering, together with guidance, would be beneficial for all stakeholders.

Main Findings: Developing a Strategic Approach to New Development

15. There were mixed responses to the question 'Do you agree or disagree with the proposals to pursue option 3. A 'locally co-ordinated approach'?' 22 respondents agreed, particularly those in the environmental and energy advisory group, public sector / delivery agency / regulators, local authorities and planners as well as individuals. 26 respondents disagreed, including 15 from the onshore wind industry group.

16. The key themes from those who disagreed with the proposal focused primarily on competitive commercial interests, confidentiality issues and differing time-plans / schedules. The main themes from those respondents who agreed with the proposal reflected the benefits highlighted in the draft Onshore Wind Policy Statement. Suggested areas of local co-ordination that might reduce costs in the development process included access, grid and radar mitigation.

17. When asked whether they agreed with continuation of the Scottish Government's 'business as usual' approach, 33 respondents agreed and 14 disagreed. The highest incidence of agreement came from within the onshore wind industry and the local authorities and planners groupings.

18. A key theme was that the system had worked well thus far and would continue to deliver projects that would help the Scottish Government to achieve green energy targets. Despite this support, a further major theme, both from those agreeing and from those who neither agreed nor disagreed, was that some modifications or further improvements could be made.

Main Findings: Barriers to Deployment

19. 33 respondents agreed with the Scottish Government's proposal to facilitate a strategic approach to the access to, and the cost of using, data from civil aviation radar to mitigate impacts of wind development on civil aviation operations. Six respondents disagreed.

20. The main themes related to hope that the proposal will lead to more wind schemes proceeding and that the costs of radar mitigation solutions have been a barrier.

21. 25 respondents, predominantly from the onshore wind industry, agreed with the Scottish Government proposal that the exclusion zone round the Eskdalemuir array should be set at 15 km. Four respondents disagreed.

Main Findings: Protection for Residents and the Environment

22. There were some generally supportive comments on the Peatland Policy Statement and/or the carbon calculator. However, many respondents, particularly from the onshore wind group, suggested that the carbon calculator and peat map do not add any significant value to the consenting process.

23. There were comments in this section on other issues in the consultation including wind farm impacts, house prices and electricity networks.

Main Findings: Community Benefits

24. There was widespread comment that the Scottish Governement's Good Practice Principles on community benefits from onshore renewable projects have had a positive impact.

25. A key theme, from across respondent groups, was support for the idea that new community benefit packages may be required to reflect new business models. Respondents from the onshore wind industry commented particularly that the community benefit package needs to be revised in line with subsidy reductions.

26. Another main theme was support for continuing to deliver community benefits in some form going forward.

27. A relatively large number of respondents felt that community benefits packages were being delivered, although a small number felt this was not always the case or were more equivocal in their views.

Main Findings: Shared Ownership

28. A relatively common theme here is that lack of skills and resources can be barriers to shared ownership schemes. Whilst the support provided by the Community and Renewable Energy Scheme ( CARES) was noted by some respondents, it was a relatively common theme that additional support from government is needed. The main emerging themes regarding further support related to funding and to ensuring provision of a range of advice, including technical, commercial and financial.


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