Chapter 3: Barriers to Deployment: Technical and Reserved Matters
3.1.1. The issue of the Eskdalemuir Seismic Array, the impact of turbines on its operation and the effective moratorium on development that the exhaustion of the 'noise' budget has led to since 2018, is covered in more detail in Annex 1. We consulted upon these issues as part of the 2017 Onshore Wind Policy Statement and continue to consider these alongside the Eskdalemuir Working Group, which was reconvened in 2018.
3.1.2. The 50km consultation zone around the array covers an area of almost 8000 km2, which is approximately 10% of Scotland's land mass. The Scottish Government recognises that this is a material barrier to the deployment of onshore wind in Scotland, and is consulting alongside this document on new policy related directly to the array and informed by seismological data and interpretation over the last 18 months. The consultation document is available at Annex 1, where further details and specific consultation questions can be found.
3.2. Aviation and Renewables
3.2.1. 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. The development of sites for wind turbines has the potential to cause a variety of negative effects on aviation. These include (but are not limited to): physical obstructions; the generation of unwanted returns on Primary Surveillance Radar (PSR); adverse effects on the overall performance of CNS equipment; and turbulence.
3.2.2. Simply put, both onshore and offshore wind turbines have the potential to disrupt radar as they are very tall objects whose blades rotate at speed. This can cause distracting false returns for operators, or 'clutter' on the display, which can mask the true position of aircraft.
3.2.3. In the past, bespoke solutions to alleviate specific individual objections arising from impacts on aerodrome surveillance equipment have been very successful, with significant GW of development enabled following the implementation of mitigation solutions.
3.2.4. Although this model has proven that collaborative work between these two sectors can produce positive results, it has not been conducted under or as part of a coordinated strategy, meaning that opportunities to learn from good practice have not always been available. This has led to a sub-optimal, fragmented approach which risks us being unable to go far enough, or fast enough, to meet our collective, and legally binding, net zero obligations and ambitions while ensuring the safe and efficient operation of Scotland's airspace is not compromised.
3.2.5. The previously successful deployment of mitigation solutions has mainly been achieved through the renewables industry investing in surveillance technology, and/or coming to a contractual arrangement to pay the aerodrome stakeholder for work required to service any mitigation solution. This was based upon onshore wind developments having an impact upon aviation operations at a time when wind farms were a more novel landscape feature, and hence being considered liable for the cost of mitigation.
3.2.6. However, wind farms have been an established part of the landscape for well over a decade now, and will play an essential part in realising the Scottish and UK Government's net zero commitments. Given this, and the potential for future technological developments to reduce the need for bespoke mitigation solutions, such as the advancement of surveillance technologies, there is an expectation that responsibility for these issues will transition from the renewables sector to the aviation sector.
3.2.7. The installation of mitigation measures should be bound by fair and transparent processes that support a cost-neutral principle. This formed the basis of the Aviation 2030 Vision Taskforce, with the aim of bringing the civil aviation and renewables sector together to focus on a transition of responsibility by 2030.
3.2.8. The Covid-19 pandemic has had a significant impact on the aviation sector over the last 12-18 months. As countries reacted to the spread of the virus with travel and living restrictions as well as closed borders, aviation suffered a major loss of traffic with flights falling by in excess of 85% in comparison with 2019 traffic levels. This reduction resulted in a severe loss of revenues for ANSPs, airports and airlines alike. The ongoing uncertainty, about the speed at which the number of flights will recover, has resulted in a number of airports pausing their airspace modernisation programmes, and is also expected to affect their ability to make significant capital investments. Job losses at airports have also led to knowledge loss within the industry and it will take time for this to be regained as the sector recovers.
3.2.9. Although COVID-19 issues affected the development of the Aviation 2030 Vision Taskforce over 2020, good 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 to agree how these will be achieved.
3.2.10. We believe that the contribution of wind energy towards meeting net zero can only be achieved if aviation and wind turbine co-existence forms part of a greater, overall strategy. The development and agreement of high-level guidance for these sectors could potentially secure important cross-industry and cross-policy benefits.
Aviation and Renewables Collaboration Board
3.2.11. The Scottish Government proposes to form a high-level group tasked with mapping the opportunities, risks and challenges associated with continued development and co-existence of these sectors. This group will not have a technical focus, but may direct sub-groups to assess and evaluate technical aspects where it deems it necessary or useful.
3.2.12. This group will ensure that good lines of communication remain with the Offshore Wind Industry Council (OWIC) Sector Deal Aviation Workstream, the Aviation Management Board, UK Government Ministerial Delivery Group, the SEAB: Task Force for Economic Recovery in the Energy Sector, CAA, AOA, CAST, ACOG Programme Board, ScTMA technical working group, the relevant Strategic Leadership Groups and any other relevant boards covering regulatory and policy change. This will prevent duplication of efforts and promote good practice around data sharing and collaborative working.
3.2.13. The group will consist of high-level members, with the ability to speak authoritatively for their organisations, to ensure speedy progress and acceptance of responsibility for this work at a corporate level. We propose that this group should meet quarterly initially, but will provide the necessary oversight, authority and commitment to ensure that the work of the programme can be progressed by its sub-groups.
3.2.14. We would expect this group to consider the high-level issues and areas where increased collaboration can help these sectors on the pathway to their net zero obligations, and to direct the delivery of specific and implementable guidance and solutions on these issues. They may also consider the potential of producing a joint renewables and aviation roadmap, or a joint aviation and renewables target based on GW release and CO2 reduction. Progress reports will be expected quarterly, with significant progress having been demonstrated within the first 18-24 months of formation.
3.2.15. More information on this board, including draft objectives and terms of reference, can be found at Annex 2 of this document.
3.3. Aviation Lighting
3.3.1. Aviation lighting is becoming a more prominent issue, one which could have a significant effect on the development of onshore wind, and a wide variety of stakeholders hold different views on how to resolve it.
3.3.2. Work is underway on technical and airspace-related solutions to these issues, and we have no intention of duplicating this or placing any additional burden on those undertaking it. Where we see a gap is in the area of practical guidance on the assessment of the aviation lighting aspects of wind farm proposals, where advice from the various bodies can be unclear.
3.3.3. The Scottish Government has set up a short-term working group (anticipated lifespan of 18-24 months) 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.
3.3.4. We expect that this working group will feed into the previously mentioned Aviation and Renewables Collaboration Board, sharing progress and outcomes, and ultimately taking direction where necessary.
3.4. Grid, Networks and Regulation
3.4.1. The required uplift in onshore wind capacity highlighted throughout this consultation will create demands for our energy infrastructure. New developments will need to be able to connect quickly and affordably to Scotland's distribution and transmission networks, and these networks must be able to manage this output and ensure that it is able to reach or satisfy demand in the most useful and efficient manner.
3.4.2. The Climate Change Committee estimates that, by 2030, annual investment of £5 billion will be required in the UK's energy networks. It's already clear that we will need new and upgraded network infrastructure to connect and transfer the Scottish renewable generation that will support net zero here in Scotland, but also across GB more widely. What's less well defined at present is the pace at which this can be delivered, the costs for Scottish generators of connecting to and using this infrastructure, and the ways in which flexibility and storage can help manage and enhance the output from wind generation across our networks.
3.4.3. Delivering network infrastructure in a timely fashion will require agile regulation working in coordination with well evidenced policy drivers and efficient consenting and planning processes. Electricity policy and regulation are reserved issues, and the responsibility of the UK Government and the independent energy regulator, Ofgem – with whom the Scottish Government will continue to engage closely across a number of key areas.
Aligning Policy and Regulation
3.4.4. 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 clear 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.
3.4.5. We continue to believe that this change is necessary and will provide helpful clarity. In the meantime, however, the regulator continues helpfully to make clear its determination to help achieve net zero while protecting customers. Ofgem is also a valuable and constructive participant in a number of important Scottish Government policy fora considering these issues.
3.4.6. For example, Ofgem is a member of the Scottish Government's Energy Networks Strategic Leadership Group. This Group agreed and published a set of principles during 2021 which recognise the importance of taking into account devolved policy and targets in regulatory decision making. These principles recognise the need for network companies and Ofgem to work within the existing GB regulatory system, while also responding to the democratic mandate of the Scottish Government to deliver policy in areas of devolved responsibility.
3.4.7. We know that transmission charging remains a barrier, and a particular disadvantage, for projects located in Scotland or Scottish waters. A number of charging reviews currently underway risk increasing some of these costs further. The pressure to achieve reductions in these charges is more acute in Scotland due to the higher transmission charging costs (TnUOS) faced by generators here, as a result of their greater distance from GB's main centres of demand.
3.4.8. These charges and this system reflect an approach whose logic and design has been overtaken in large part by the fact of the global climate emergency, and the essential role of onshore wind and other forms of renewable electricity in decarbonising energy demand across our society and economy.
3.4.9. Ofgem has recently provided a welcome signal that it intends to review transmission charges. Pending this review, however, Ofgem's minded-to position following its recent review of access and forward looking charges has signalled that it still intends to apply TnUOS to small (less than 100MW) distribution-connected generation, which could be particularly detrimental to Scottish renewable developments and to investment in new onshore wind capacity. The Scottish Government understands the objectives of these reforms, but remains concerned that they are out of step with the need to achieve net zero.
Network Investment and Planning
3.4.10. The Scottish Government has been engaging closely with the process of developing the next set of regulatory price controls (RIIO2), focusing in particular on ensuring that Scottish energy policies, targets and priorities are taken into account as fully as possible. Decisions made under RIIO-2, and the energy infrastructure delivered as a result, will be critical to achieving our climate change and net zero commitments. This will need agile and responsive regulation, including the use of net zero reopeners, which Ofgem has made clear that it understands and aims to ensure. There is also a crucial role for anticipatory / strategic investment, as well as innovation.
3.4.11. The way in which network infrastructure is planned and delivered, and the efficiency and speed at which this can be achieved, is another crucial area. We are working with the Scottish transmission owners, Ofgem and others on network planning issues, recognising and including the Scottish Government's role in considering and determining applications for consent to build overhead electricity lines within Scotland.
3.4.12. Our aim will be to manage these processes in as streamlined and co-ordinated a fashion as possible – for example, taking into account interdependencies and linkages with the development of offshore HVDC links and the need to connect our huge offshore wind potential – and to consider community awareness and engagement as well as issues such as supply chain and economic benefit.
Security of Supply / Storage Potential
3.4.13. We believe that onshore wind can play a greater part in helping to address the substantial challenges of maintaining security of supply and network resilience in a decarbonised electricity system. This will mean an increasing ability to provide some of the services and responses that are currently provided by thermal generation, and market / regulatory arrangements which can incentivise and support such outcomes.
3.4.14. The Scottish Government has helped enable a project which underlined some of the potential here. We provided £550,000 to support a demonstration project delivered by Scottish Power Renewables at its Dersalloch Wind Farm, looking at the potential for delivering black start from wind. The project delivered a global first during a test in October 2020 by delivering black start capability from wind power to re-start part of the electricity system.
3.4.15. More innovation of this kind can help onshore wind to play as full a part as possible within a net zero electricity network. However, there are other means by which onshore wind output can be managed and help assist the operation of the system.
3.4.16. These include the potential of co-location with forms of storage, such as hydrogen electrolysers. The green hydrogen produced from such processes can serve a number of highly valuable purposes; in addition to greatly reducing constraint payments and costs, the green hydrogen produced could help meet demand for zero carbon heat and transport energy as well as being used to generate electricity and provide vital flexibility at key strategic locations on the network.
3.4.17. We have already seen an increase of onshore wind developments co-located with battery storage facilities and, as we continue to progress towards the decarbonisation of our energy system, battery storage will be more and more prevalent. On-site battery storage not only removes pressures from the grid, but enables more locally focussed energy provision, and reduces costs to consumers.
3.4.18. The Scottish Government will continue to support the co-location of both battery storage and hydrogen production facilities with onshore wind developments to help balance electricity demand and supply, add resilience to the energy system and support the production of green hydrogen to meet our future demands.
Barriers to Deployment: Technical and Reserved Matters - Consultation Questions
Please note the Eskdalemuir Seismic Array policy issues are considered in a separate annex at Annex 1, this also includes specific consultation questions on that issue.
Additionally, details on the proposed Aviation and Renewables Collaboration Board are available at Annex 2, this also includes specific consultation questions on the formation of this board.
9. 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?
10. We would also be grateful for your views on network charging and any of the other aspects set out under section 3.4.
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