Onshore wind policy statement refresh - draft: consultation analysis

Analysis of the consultation responses received to the draft Onshore Wind Policy Statement between 28 October 2021 and 31 January 2022.

Chapter 2: Future Position and Net Zero

When referring to respondents who made particular comments, the terms 'a small number', 'a few' and so on have been used. While the analysis was qualitative in nature, as a very general rule of thumb it can be assumed that: 'a very small number' indicates around 2-3 respondents, 'a small number' indicates around 4-6 respondents; 'a few' indicates around 7 to 9; and 'some' indicates 10 or more but fewer than half of those who commented at any question. Where larger numbers of respondents are referred to, a 'significant minority' is 10-25% of respondents, a 'large minority' is denoted by 25-50% of respondents, and 50%+ is 'a majority'.

2.1. The consultation paper noted that the transition to net-zero means that demand for green electricity will increase substantially over the next decade. The UK currently has 14.1GW of installed onshore wind, with 8.4GW of this in Scotland. Scotland additionally has around 9.7GW of onshore wind currently in the pipeline, across 202 projects. The Scottish Government (SG) Climate Change Plan Update noted the need to develop 11-16GW of renewable capacity through to 2032. The Climate Change Committee (CCC) has additionally developed four exploratory scenarios for emissions to 2050. The SG is seeking views on an ambition for an additional 8-12GW of onshore wind to be installed in Scotland by 2030 to help meet the binding net zero commitment.

2.2. There were significant numbers of concerns from the onshore wind industry that the currently consented 4.5GW or the 4GW in the planning system will not actually be developed; reasons included a lack of financial routes to market, having to re-enter the consenting process as the original consent was under the Renewables Obligation scheme, and developments predicted as not being viable without the reintroduction of heavy subsidies like the RO or early CfD rates.

2.3. There are significant potential advantages to repowering which include the environmental benefits of re-using existing infrastructure together with maximising the generation of established sites. The consultation paper also noted that the views of the local community are important in the smooth transition of repowering proposals through the planning and consenting system.

2.4. Question 6 of the consultation asked:

Q6: What are your views on the installed onshore wind capacity that will be necessary over the coming decade, recognising the ambition Scottish Government have proposed for 8-12 GW? Please share any evidence.

Summary (Q6)

  • General support was expressed for the target, though there was some disquiet over the use of the word 'ambition' as it could allow for backsliding.
  • A need was seen for a more holistic approach to target setting in concert with other renewable energy forms, in particular offshore wind.
  • Repowering existing onshore sites with larger and more efficient turbines was favoured in order that the task of realising the ambition is not undermined by the end of lives of currently operational wind farms.
  • Planning system support and a quicker process for consents were reiterated as enablers.
  • There were some concerns from the renewable energy industry that the currently consented 4.5GW or the 4GW in the planning system will not actually be developed because of a lack of viability or routes to market.

2.5. A total of 127 respondents chose to respond to this question. General support from a large minority (including a large number of renewable energy respondents) was expressed in favour of the 8-12GW target, with comments that it meets the levels of output defined by the Climate Change Committee (35GW), and recommended by RenewableUK in the Onshore Wind Prospectus (30GW). Furthermore, a significant minority of mostly renewable energy and communities' organisations continued on to say that this was a good starting point for more ambitious long term targets (e.g. beyond 2030). A significant minority mostly consisting of renewable energy organisations had concerns over the use of the word 'ambition', thinking this might allow for backsliding or be a reason for projects to be refused; these respondents preferred a fuller commitment to the 12 GW target. At the same time similar numbers of respondents from across the sub-group spectrum expressed doubts that the targets can be met, with a few stating that the share prescribed to onshore wind was unattainable. A small number of mainly local authorities and planners were concerned to know how the targets were arrived at.

2.6. The largest numbers of respondents – a large minority with at least 25% of respondents from each of the communities, government funded, lobby and interest, local authority and planning and individuals sub-groups - saw a need for a more holistic approach to target setting, i.e. that there should be a joined-up approach between renewable energy solutions including solar, tidal, nuclear and community-owned renewables as well as electricity conservation measures; many of these respondents wanted a particular focus on offshore wind which was regarded as having greater potential capacity having just sold 25GW of offshore sites.

2.7. Repowering existing onshore sites with larger and more efficient turbines was favoured by a significant minority of mainly renewable energy and local authority and planning respondents as a means of either ensuring that realisation of the ambition was not undermined by the problem of a number of currently operational wind farms coming to the end of their lives, or (as perceived by a small number of respondents across several sub-groups including two from the renewable energy industry) in itself making a large contribution towards the target. Several advantages were cited including fewer environmental impacts compared to new sites, little requirement to expand acreage or access roads and sites already having grid connections. There were however a few concerns that repowering alone will not sufficiently increase onshore capacity to meet the climate change targets, and that larger turbines need more space (such that some sites may not be appropriate) and an increase in grid connection capacity, as well as needing to go through the same planning process as new developments.

2.8. Planning system support was recommended by a large minority of mainly renewable energy respondents, especially in order to adapt to the use of longer turbine tip heights and to review the approach to assessing visual impacts and landscape capacity. A quicker process for consents (currently averaging 7 years) was urged, together with more resources for planning authorities.

2.9. On a related point, further potential detrimental impacts on the possibility of achieving the 8-12GW target were raised concerning the draft NPF4; implicit support was urged within this for onshore wind, with a disconnect with the OnWPS being identified. A need to ensure positive biodiversity effects within both documents was pinpointed, as well as the effectiveness of peatland management plans. The loss of the onshore wind spatial framework was regarded as a backward step.

2.10. Further issues were raised concerning attempts to increase the number of wind farm developments in order to achieve the 2030 target, mostly by a large minority comprising mainly local authorities and planners, individuals, communities' organisations and lobby and interest groups. These were as follows:

  • Concerns over some areas becoming saturated with onshore wind farms (e.g. Aberdeenshire) with suggestions to try to locate more wind farms close to areas of high electricity consumption.
  • Concerns over choosing the best designs for the right sites.
  • Concerns over the best sites already having been developed and there being not enough unconstrained land available to meet targets because of factors including aviation, MoD sites, grid access, environmental constraints, landscape, designated Wild Land areas and industrial use policy.
  • Concerns over other detrimental impacts incurred by the presence of large numbers of wind farms and larger turbines, such as the destruction and exploitation of rural areas and communities, biodiversity and peatland impacts, and tourism impacts.
  • Concerns about a lack of base load or back up power.
  • Concerns over household affordability in terms of increasing energy charges.

2.11. A few respondents (mainly renewable energy and local authority and planning bodies) were of the opinion that much would depend on grid infrastructure investment in terms of transmission lines and connections.

2.12. A few communities' groups and individuals reiterated that there should be no more onshore wind developments, citing intermittency of energy, ruined landscapes and the benefits accruing to private investors despite public money input.

2.13. Several respondents including renewable energy, government funded, lobby and interest and local authority and planning bodies and individual respondents, referred to research, reports and other analysis within their answers. The Committee on Climate Change estimates of requirements was most regularly referred to by respondents; other references are listed in Appendix 2.

2.14. Question 7 then went on to ask:

Q7: What more can be done to capture the potential and value of hydrogen production from onshore wind and how best can we support the optimal integration of these technologies?

Summary (Q7)

  • Support was expressed for hydrogen production in theory as a good use of excess power generation, albeit it was noted that hydrogen production technology still has a long way to develop.
  • Recommendations for development were that it needs to be done at scale to be economic, be carried out close to demand centres, requires large scale storage and needs financial, planning and strategic support.
  • Concerns were noted regarding the use of resources to produce green hydrogen, transportation and storage difficulties and costs of production; a focus on other already available energy storage solutions was mooted.

2.15. A total of 96 respondents answered this question. A large minority from all sub-groups were supportive of hydrogen production in association with wind farms, at least in theory, with some of these supportive of the Scottish Government's green renewable hydrogen target of 3GW by 2030. However, similar numbers of respondents, including many of the supportive respondents, noted that hydrogen production technology still has a long way to develop, with queries over its expense, whether this is feasible to carry out at large scale and where to build hydrogen production facilities.

2.16. A large minority of respondents mainly consisting of renewable energy, local authority and planning, and government-funded bodies and regulators, made comments outlining recommendations as to what needs to be done to enable value to be gained from hydrogen production, as follows:

  • Hydrogen production, whether by electrolysis or fuel cell technology, needs to happen at scale as there is a critical mass required to be economically viable.
  • There is a need to view hydrogen as part of the overall energy production landscape regarding energy demand, with a few remarks that it should be reserved for applications where there are no other options.
  • Large scale storage needs to be available, with recommendations for the development of hydrogen hubs.
  • Hydrogen production should be carried out close to demand centres, where there are known and reliable offtakers for energy produced (e.g. ferry terminals or distilleries) and costs of storage and transportation can be kept down.
  • Financial support to be provided (e.g. financial mechanisms, subsidies, tax breaks, incentives, allowances or minimum market price provision).
  • Planning and consenting support (e.g. additional weight given in planning to projects involving hydrogen production, new permitted development rights introduced for hydrogen production and storage in existing wind farms).
  • Support should be ingrained in NPF4 and other strategies or plans such as Regional Spatial Strategies and Local Development Plans (e.g. in order to co-locate with other renewable energy projects). A few respondents saw a need for a specific hydrogen action plan such as the Scottish Government's draft plan to establish processes and guidelines for projects.

2.17. Benefits from hydrogen production were foreseen by a significant minority of respondents from a wide range of sub-groups; in particular that it would be a good use of excess power generation such that constraint payments can be reduced or eliminated, with a small number of mentions that hydrogen can potentially replace natural gas, or supplant LNG in areas off the mains gas network. There were also a few calls for localised or community-led hydrogen generation.

2.18. There were a small number of calls from renewable energy respondents to distinguish between blue and grey hydrogen, and green (renewable) hydrogen production, such that blue hydrogen production should not be regarded as low carbon. A similar number of mainly individual respondents perceived that hydrogen production does not all need to come from onshore wind, citing an array of other means including offshore wind, microbes using light, converting biomass into gas or liquid and separating the hydrogen, production using carbon capture, stable hydropower and slurry. Equally, a few mainly communities' respondents perceived that onshore wind can support other renewable energies such as hydro and clean motor fuel.

2.19. A significant minority of respondents from across almost all sub-groups, nearly half of whom were otherwise generally supportive, perceived the following concerns and issues with hydrogen production:

  • Worries about the resources needed to produce green hydrogen with clean water availability, rare earth elements use in electrolysers and the large amounts of renewable energy needed for conversion all specifically mentioned.
  • Transportation difficulties.
  • Storage difficulties (e.g. costs, leakages, security).
  • Fire hazard potential.
  • Costs of production.
  • Emissions of nitrogen oxides when burned.

2.20. A similar number of respondents – communities' organisations and local authority / planners in particular – thought it better to focus on other, already available, energy storage solutions such as pumped hydro storage and battery storage. A small number of respondents voiced a preference to develop other technologies (e.g. small modular nuclear reactors, fusion energy or fuel cell technology).

2.21. The consultation paper then noted Scotland's ambition to produce low-cost, clean hydrogen as a potential replacement for fossil fuel feedstock in industrial and chemical processes, and the use of onshore wind to support a future hydrogen infrastructure. The Local Energy Policy Statement Delivery Framework set out a number of actions to be taken forward to enhance Scottish Government support for community led activity.

2.22. Question 8 then went on to ask:

Q8: In what way(s) can we maximise the benefits of repowering over the coming decades?

Summary (Q8)

  • General approval was expressed for repowering as a means to avoid capacity losses due to the end of life of existing wind farms, and of alleviating the need to build in new areas resulting in fewer environmental impacts.
  • Help to maximise the benefits included enshrining a presumption in favour of repowering within consent and planning regulations and extending or removing time limited consents in order to extend the life of wind farms.
  • Further actions recommended were working with communities to mitigate issues arising from larger turbines or to have a stake in projects and their benefits, and exploiting circular economy opportunities to recycle or reuse turbine materials.

2.23. A total of 120 respondents made comments about repowering. A large minority across most respondent sectors stated general approval of repowering, commenting that it was a substantial opportunity to avoid the undermining of increased capacity goals caused by the end of life of currently operational wind farms, or (as perceived by a few mainly onshore wind respondents) would help in delivering the additional power capacity required, given the chance to use advances in technology. A significant minority from all sub-groups added that repowering was better than building in new areas as this would impact less on wildlife and peat bogs and lead to fewer potential conflicts and therefore should be encouraged over new onshore developments.

2.24. A large minority, mostly comprising renewable energy organisations, wished to enshrine a presumption in favour of repowering within consent and planning regulations; it was thought there was a need to acknowledge that wind farms were already in operation on a repowering site. Support, it was inferred, would be needed from the NPF4 and OnWPS, with suggestions for a proportionate approach to EIAs or permitted development rights. To help facilitate repowering activity, almost as many respondents, again dominated by renewable energy organisations, urged the extension or removal of time limited consents to extend the life of wind farms. A significant minority (almost all of them renewable energy respondents) foresaw a need to consent larger and more efficient turbines and larger site areas to accommodate them in place of smaller ones; landscape capacity studies were seen as being a particular impediment to this. Furthermore, it was pointed out by similar numbers of respondents that not all developments are suitable for being consented for repowering projects because of the greater scale required and longer life needed.

2.25. A large minority of respondents from most sub-groups, but particularly including communities bodies, focused on the need to work with communities in order to maximise repowering benefits, citing increased turbine heights as requiring an increased buffering distance to avoid being detrimental. Further comments included requests to let communities have a stake in, or ownership of, repowering projects and reiterating possible uses of community benefit packages such as free or subsidised electricity, training, improved broadband and directing benefits towards climate action.

2.26. A significant minority of respondents, particularly including local authorities and planners, were keen to exploit circular economy benefits from repowering; specific facets mentioned were the opportunities to recycle or reuse turbine materials and components, refurbish old turbines with more efficient blades and reuse old grid infrastructure and access roads. However, there were a few concerns expressed about a perceived need for new cabling and transmission infrastructure and new foundations.

2.27. Other advantages of repowering were mentioned by a significant minority of mainly renewable energy respondents, as follows:

  • The opportunity to deploy technology developments (e.g. more efficient turbines, capturing more energy from the same heights).
  • Economic benefits (e.g. creating jobs in the supply chain).
  • Benefits from reduced development costs and risks.
  • Increased opportunities for hydrogen production.

2.28. A significant minority of respondents from a mix of sub groups including notable proportions of local authorities / planners and lobby and interest groups had concerns about increased negative effects emanating from repowering projects such as environmental and visual impacts, noise and shadow flicker all being exacerbated by the presence of larger turbines.

2.29. A small number of comments perceived that repowering on its own will not achieve Net-Zero Carbon targets without new wind farms and extensions being added. Similar numbers continued to advocate the use of other renewable technologies in preference to onshore wind.


Email: onshorewindpolicy@gov.scot

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