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.

Annex 2: Aviation and Renewables Collaboration Board

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'.

1. The Scottish Government is proposing the formation of a high-level group tasked with mapping the opportunities, risks and challenges associated with continued development and co-existence of these sectors and outlined a number of issues for consideration.

Summary (Qs30-31)

  • There was a broad welcome, mainly from renewable energy respondents, to the idea of the Aviation and Renewables Collaboration Board and the proposed restructuring of activity in the aviation area. A collaborative approach was supported in order to involve as wide a variety of stakeholder groups as possible.
  • Aviation safety was urged to be paramount.
  • Clear terms of reference and a more technical focus was advised regarding the policy remit. Equal numbers of respondents thought windfarm developers and the government should meet the financing of technical or strategic investments.

2. Question 30 asked:

Q30: We are clear on the value and importance of strategic and productive collaboration between the aviation and wind energy sectors. What are your thoughts on our proposed restructuring of the current effort and activity in this area, and the proposed Aviation and Renewables Collaboration Board?

3. A total of 48 respondents from most sub-groups made comments at this question. A majority, particularly from the renewable energy grouping, welcomed the proposed Aviation and Renewables Collaboration Board and proposed restructuring of efforts in the area, also welcoming a transition of responsibility for aviation issues to the aviation industry. A majority, consisting mainly of renewable energy, aviation and individual respondents, also supported a collaborative approach, with comments about being open to as wide a variety of stakeholder groups as possible to ensure a range of views, and a UK-wide approach as aviation is a reserved sector to the UK Government. In particular, collaboration was seen as needed with the BEIS-led Aviation Management Board, the Offshore Wind Industry Council (OWIC) and the RenewableUK Aviation Working Group.

4. A significant minority made up of entirely renewable energy respondents suggested representation; bodies mentioned included the Defence Infrastructure Organisation (DIO), Defence Airspace and Air Traffic Management (DAATM), RAF Capability Strategy (RAF Cap Strat), Defence Equipment and Support (DE&S), and in particular the MoD. Developer and community representation was also recommended.

5. A significant number of respondents, including all the aviation specialist sub-group and a range of other sub-groups, urged that aviation safety be paramount, highlighting the following:

  • Concerns that only a third of the proposed board have connections to aviation.
  • Airports may not have the money to spend on the upgrades required to safeguard flights through busy windfarm territory.
  • Radar interference needs total mitigation.
  • Concerns about distractions on operators' displays.
  • A need to clearly demarcate areas where turbines cannot be built for aviation reasons.
  • A need to mention aerodrome safeguarding and other safeguarding impacts (e.g. Communication, Navigation and Surveillance (CNS) equipment and turbulence and issues with increased turbine height due to repowering).

6. A few respondents, again consisting mainly of aviation specialists, had concerns that the aviation industry will now share costs; these respondents felt that the commercial companies promoting their developments should pay.

7. On the proposed policy topics, a significant number consisting almost entirely of renewable energy and aviation respondents thought the list was too broad a remit (e.g. areas such as carbon neutral campuses and electric vehicle usage not being under the specific remit of aviation) and that more technical focus and clear terms of reference were needed. A very small number (all of whom were aviation specialists) felt that the policy issues were too prescriptive and that the Board needed flexibility to develop its own terms of reference.

8. Further comments from a few mostly renewable energy respondents recommended that the Board should learn from the (successful) equivalent offshore wind programme (OWIC), and urged that barriers to deployment of wind farms caused by aviation need to be addressed, in particular advocating that aviation objections on radar interference grounds should not be valid where the operator already uses – or is in the process of procuring – a wind farm tolerant radar or radar feed, or ensuring the aviation and defence sectors take responsibility for procuring windfarm tolerant radar in their next procurements.

9. The final question in the consultation paper then asked:

Q31: The work of the Aviation and Renewables Collaboration Board may identify and agree the need for technical or strategic investment to achieve specific goals or outcomes. What are your views on how work of this kind might be financed?

10. A total of 49 respondents from most sub-groups made comments at this question. Opinions on funding technical or strategic investment were polarised: equal numbers vouched for wind farm developers (mainly aviation specialist and individuals), and for the government (broad mix of sub-groups) to meet all costs, with fewer respondents (from a broad mix of sub-groups) stating funding should be by the aviation industry.

11. Reasoning for wind farm developers meeting all the costs, advanced mainly by individuals, aviation specialists and community groups, were that airports and aircraft were in use before wind farms; that those who benefit commercially should pay; and that there is little justification for aviation stakeholders to invest in resolving the impacts of third party commercial activities. There were suggestions of a mandatory levy on developers to fund the Board's activities, or an annual charge for air traffic mitigation requirements.

12. Government funding was recommended by a broad spectrum of subgroups, albeit with suggestions that there could be contributions from developers and the aviation industry. There were suggestions of funding mechanisms (e.g. a tax on energy producers or air departure tax proceeds) to release a central pot of money to cover the costs of mitigation actions. There was broad agreement from a range of sub-groups on the need for good governance, transparency and accountability if the government-funded approach to costs was taken. A very small number of individuals stated they were against taxpayers meeting costs.

13. A few respondents, almost all from the renewable energy industry, recommended financing by the aviation industry, particularly in the long term. Suggestions were for a tax on aviation fuel or air passenger duty, with comments that the aviation sector needs to ensure their assets are updated to a net-zero carbon world.

14. Suggestions about a joint funding approach between the renewables and aviation industries were made by a small number of respondents to help build a collaborative approach. Further mentions were made regarding a collaborative approach more generally to reach a mutually satisfactory settlement.

Additional comments

1. 30 respondents from almost the full range of sub-groups opted to provide additional information. A majority of these remarks outlined the background, role, and activities of the respondent, or reiterated their general position regarding onshore wind.

2. There were a few concerns expressed – almost all by renewable energy respondents - over planning reforms such as the need to align NPF4 with the OnWPS and perceived planning issues hindering progress towards the 2030 target.

3. Small numbers of mainly communities and lobby and interest respondents advocated a need to have more protection for and take more heed of communities, perceiving bias in favour of the renewables industry.

4. There were also small number of statements regarding individual projects and the difficulties they have faced from individual and renewable energy respondents.

5. There were a very small number of requests for greater coverage of noise issues from acoustics, legal and individual respondents.


Email: onshorewindpolicy@gov.scot

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