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 3: Barriers to Deployment: Technical and Reserved Matters

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'.

3.1. The consultation paper noted that the impact of wind turbines on aviation operations at both civil and military aerodromes has been the subject of significant work and investment over many years. Onshore and offshore wind turbines have the potential to disrupt radar as they are tall objects whose blades rotate at speed. This can cause distracting false returns for operators which can mask the true position of aircraft. Mitigation solutions have been used in the past but, as these have not been coordinated, opportunities to learn from good practice have not always been available. Previously it has been the responsibility of the renewables industry to invest in mitigation solutions. However, wind farms are now an established part of the landscape and it is now expected that responsibilities for mitigation solutions will transition from the renewables sector to the aviation sector.

3.2. The Aviation 2030 Vision Taskforce was set up and has the aim of bringing the civil aviation and renewables sector together to focus on a transition of responsibility by 2030. While COVID-19 issues affected the development of the Aviation 2030 Vision Taskforce during 2020, progress has been made on developing positive relationships, encouraging collaboration and considering the policy and regulatory framework these sectors operate in. However, the demands of net-zero require both aviation and renewables sectors to make still greater efforts to establish mutually beneficial collaboration, as well as to set and specify goals and agree how these will be achieved. The Scottish Government (SG) proposed to form a high-level group tasked with mapping the opportunities, risks and challenges associated with continued development and co-existence of these sectors.

3.3. Aviation lighting is becoming more of an issue which could have a significant effect on the development of onshore wind, and a wide variety of different stakeholders hold different views on how to resolve this issue. The SG has set up a short-term working group to consider this issue and, ultimately, to deliver practical and consistent guidance to aid both the renewables sector and decision makers in assessing these impacts.

3.4. Question 9 of the consultation paper, asked:

Q9: We would be grateful for comments on the issue of aviation lighting and suggestions for the focus and outputs of the Aviation Lighting Working Group – what are your views on the assessment of aviation lighting and how this should be undertaken?

Summary (Q9)

  • A key theme was support for the transition of responsibilities for mitigation solutions to the aviation sector, although there were some concerns over resources to support this.
  • There were references to a need for collaboration across a wide range of stakeholders; along with some comments on the structure of the Working Group.
  • A number of respondents, primarily individuals and communities groups, commented that they believed there could be damaging impacts to the tourism sector from onshore wind.
  • The provision of guidance to help with assessing impacts and providing information on mitigation measures was welcomed, although there were requests for this to be in line with other guidance and there were concerns over the cost of these measures.
  • There were some requests for better engagement with the aviation industry at the pre-application planning stage.

3.5. A total of 84 respondents opted to respond to this question. A key theme emerging from a significant minority of respondents within the renewable energy sector was support for the transition of responsibilities for mitigation solutions to be transferred to the aviation sector, albeit that a small number of respondents noted that there will need to be adequate resources to support this. A few respondents in the renewable energy sector also noted their support for this approach but felt the focus of the approach is too narrow and that it should cover aviation lighting and surveillance capabilities.

3.6. Some respondents, primarily those in the renewable energy sector and local authorities, referred to the need for collaboration, with references of the need for developers to work closely with the CAA and the aviation industry; for the Scottish Government, the UK Government and BEIS to work together to overcome the challenge of costs; and for collaboration between the CAA and the Aviation Lighting short-term Working Group. There were also a small number of references of a need to include the views of individuals and residents who may be impacted by wind turbines.

3.7. Linked to the issue of collaboration, a few respondents – primarily those involved in renewable energy – commented on the structure of the Working Group. Comments focused mainly on the organisations represented on this Group, with comments on the need to include relevant policy, regulatory and industry stakeholders and technical experts while ensuring the Group can focus on its remit and avoid becoming too large. A need to focus on delivering against priorities using a time-limited approach was also highlighted by a small number of respondents.

3.8. Perhaps not surprisingly, some respondents, mostly those in the renewable energy sector, focused specifically on roles that should be adopted by the Scottish Government. A range of different roles were noted, including the need to provide strong leadership, in establishing relevant guidance to allow the granting of planning permission or consent with conditions permitting the deployment of light minimisation strategies or supporting and promoting the use of radar activated lighting.

3.9. Another key theme emerging from a significant minority of respondents, primarily those within communities and individuals, was that of the damaging impacts of onshore wind. A number of respondents commented that they believed there could be damaging impact on the tourism sector and an allied loss of income. A key issue for many of these respondents was the impact of light pollution on Dark Sky Parks and views from wild areas, although there was also comments about the impact on residents. There were a few comments that aviation lighting presents a night-time visual nuisance, particularly where there is a strobing effect.

3.10. The provision of guidance which can help with assessing impacts and providing information on mitigation measures was welcomed by a significant minority of respondents (mostly local authorities and the renewable energy sector). There were also a few references to the need for any guidance produced to tie in with other guidance such as GLVIA3 or NatureScot Siting and Design Guidance; and to recognise environmental concerns and ensure safety standards are met. There were some comments that visualisations of night-time views of aviation lighting are not accurately represented in the planning process; for example, that showing red dots in dark environments do not present an accurate representation of how lighting is perceived by the human eye.

3.11. Allied to the issue of planning and visualisations, there were a few comments of the need for better engagement with the aviation industry at the pre-application planning stage and in dealing with the discharge of technical planning conditions to meet the 12GW of new onshore wind capacity that is required by 2030, as well as in securing repowering consents for existing operational sites. There were a small number of comments that some aviation bodies are reluctant to engage at this stage of the planning process and that this can result in delays and increased costs to developers.

3.12. The costs of mitigation measures were highlighted by some respondents within the renewable energy sector, with comments that any measures adopted need to be bound by fair and transparent processes that support a cost-neutral principle.

3.13. While the costs of mitigation measures were of concern to some respondents, a wide range of suggested measures were offered by respondents. These included:

  • Ensuring that lights are placed on outlying perimeter turbines (cardinal turbines) to guide aircraft and to limit the number of lights on individual turbines.
  • Adoption of transponder technology which is only operational when aircraft are in the area and thus limits the length of time that lights are visible on a turbine(s).
  • Changes to flight paths and heights, for example to exclude aircraft from flying over turbines or flying at a height of over 5000 feet.
  • The use of infra-red lights which are not visible to the naked eye.
  • Limiting the height of turbines to a maximum of 150 metres so that they do not require lighting. That said, there was general acknowledgement from some respondents that turbines of more than 150 metres have become the norm for both new and repowered windfarms and that the majority of recently consented windfarms will require at least one aviation light; so this needs to be an intrinsic element of any Landscape Visual Impact Assessment (LVIA).

3.14. The consultation paper noted that the required uplift in onshore wind capacity will create demands for the energy infrastructure, both within Scotland and across the UK as a whole. Question 10 asked:

Q10: We would also be grateful for your views on network charging and any of the other aspects set out under section 3.4

Summary (Q10)

  • A significant minority of respondents across most sub-groups noted concerns over Transmission Network Use of System (TNUoS) costs as well as their volatile and unpredictable nature; these were seen as a barrier to investment in new projects.
  • There were requests for TNUoS reform to reduce charges, and a perception that Scotland is disadvantaged due to its distance from demand centres.
  • In terms of network investment and planning, comments focused on a need for substantial investment in the grid along with significant upgrades to the grid network to allow for projects of greater capacity to connect.
  • Respondents perceived a need for the Scottish Government to work with industry, TOs, DNOs, Ofgem and other UK administrations.
  • In relation to security of supply / storage potential, there was general agreement with the co-location of onshore wind with battery storage and hydrogen production, although there were some concerns that storage potential is problematic.

Network Charging

3.15. The consultation paper highlighted that a particular disadvantage for projects in Scotland is network charging whereby there are higher transmission charging costs faced by generators as a result of their greater distance from Britain's main centres of demand. Furthermore, a number of reviews currently in place risk increasing some of these costs. While Ofgem has recently signalled that it intends to review transmission charges, it has also signalled that it intends to apply TNUoS to small (less than 100MW) distribution-connected generation.

3.16. This was the area attracting most comments from respondents, with a number of key themes emerging. A significant minority of respondents across most sub-groups, with the exception of respondents in the acoustics, aviation specialists and third sector sub-groups, commented that TNUoS costs are too high due to the higher transmission charging costs because of the distance from the centre of demand. Respondents in the renewable energy sector commented that this represents the biggest single operational cost and is a barrier to investment in new projects where natural resources are plentiful.

3.17. Allied to this point, there were also comments from a significant minority of respondents – mostly respondents in the renewable energy sector – on the volatile and unpredictable nature of TNUoS which is not cost reflective of actual investment in the networks and presents another barrier to renewable generators.

3.18. There were suggestions from some respondents across a range of sub-groups of a need to quickly bring about TNUoS reform and reduce charges to create a more even playing field. One respondent in the Governmental funded bodies & regulators sub-group noted that current TNUoS changes are based on an outdated system which does not reflect the decentralised generation model that has developed.

3.19. While there was a general perception that Scotland is disadvantaged due to its distance from demand centres, there were some specific references to the very high charges imposed on island generators, particularly those outwith the Main Interconnected Transmission System (MITS). There were a small number of comments welcoming the recent Ofgem decision to approve the Shetland HVDC link project. Allied to this issue, there were a small number of comments that projects are being pointed towards England as a centre of demand which is at odds with the Holyrood and Westminster governments approach to direct projects towards Scotland and Wales.

3.20. A small number of renewable energy organisations noted the next set of RIIO2 price controls (Revenue = Incentives + Innovation + Outputs) need to deliver investment to ensure enough reinforcement of the grid is in place for renewable generators to connect and repower.

3.21. The consultation paper noted that the Scottish Government has been engaging closely with the process of developing the next set of regulatory price controls (RIIO2), focusing on particular in ensuring that Scottish energy policies, targets and priorities are taken into account as fully as possible. Two key themes emerged in relation to this specific issue.

3.22. The first theme focused on the need for substantial investment in the grid, and significant upgrades to the grid network to allow projects of greater capacity to connect, cited by respondents across most sub-groups. There were some concerns that the additional low carbon generation that is needed to deliver net zero ambitions will be delayed by a lack of grid capacity. There were a small number of suggestions for decentralised generation capacity.

3.23. The second key theme which emerged was a perception that energy generation should be sited close to the source where it is needed, purportedly in order to minimise transmission losses (mentioned primarily by communities and individuals). That said, in most cases this would not be possible given a lack of wind power – and therefore an inability to produce energy – in many areas such as cities and towns.

3.24. A few respondents in the renewable energy sector and local authorities referred to the need for a strategic approach to onshore wind. This includes identifying areas with potential capacity where large schemes can be delivered and capacity can be built into nearby substations or distribution networks to assist in delivering projects and outputs more quickly. One energy company noted the need to have a national strategy plan that would set out the necessary investment in the UK transmission system to achieve 2030 goals. An organisation in the lobby and interest group sector noted the need to plan for additional energy infrastructure which will minimise transmission losses and avoid sensitive environmental areas.

Aligning Policy and Regulation

3.25. The consultation paper commented that the Scottish Government welcomed the commitment in the UK Energy White Paper to consult this year on a draft Strategy and Policy Statement (SPS) for Ofgem, which will include a requirement for Ofgem to carry out its regulatory functions in a manner consistent with net-zero, and the delivery of an energy system which can enable that outcome.

3.26. The key theme emerging here from some respondents, mostly in the communities and renewable energy sector, was of a need for the Scottish Government to work with industry, TOs, DNOs, Ofgem and the other UK administrations to discuss the grid infrastructure, transmission networks, regulation and charging policy. A few respondents, primarily from the renewable energy and legal sectors reiterated the need for regulatory policy to align with the UK and Scottish Government net-zero targets and of a need for this to be embedded in Ofgem's decision making framework.

3.27. There were a small number of comments that there may be opportunities through NPF4 to secure greater collaboration between stakeholders and ensure a better fit between renewable energy capacity and infrastructure investment. However, an energy organisation noted that at present NPF4 is misaligned with what is proposed in this consultation paper, and that planning and consenting needs to be recognised as a possible delivery barrier.

3.28. Once again, there were references to the need for strategic, anticipatory investment across the onshore and offshore transmission networks, for co-ordination between energy networks and for centralised planning to deliver net-zero ambitions.

3.29. The consultation paper noted that onshore wind can play a greater part in helping to address the challenges of maintaining security of supply and network resilience in a decarbonised electricity system. It also noted the potential of co-location with forms of storage, such as hydrogen electrolysers; additionally on-site battery storage removes pressures from the grid and also enables more locally focused energy provision as well as reducing costs to consumers.

3.30. The key comment in relation to this was agreement with the co-location of onshore wind with battery storage and hydrogen production and that this would help to take pressure off transmission and distribution constraints that are currently in place. However, there were also some comments that storage potential is problematic and there is a need to consider how to develop storage facilities. There was also a comment that TNUoS is currently a major barrier to large scale storage projects.

3.31. A few respondents, mostly individuals, pre-empted some of the questions in the following section of the consultation paper and highlighted environmental concerns. These primarily focused on onshore cabling causing damage to scenery and wildlife and a greater need to consider the natural heritage in relation to windfarm applications. For example, there is a need to assess the risks to sensitive soils and watercourses where co-location is being considered; modifications made to the carbon calculator on peatland sites; or to ensure that appropriate economic, environmental safety and carbon calculations are included in EIAs.


Email: onshorewindpolicy@gov.scot

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