4. Developing A Strategic Approach To New Development
A strategic approach, based upon an analysis of both wind speeds and landscape capacity, may allow for a rationalisation of existing wind farm developments and/ or the identification of new sites where the greatest yield could be achieved within appropriate landscapes.
The following section refers to section 36 determinations only (Scottish Ministers consider applications for generating stations in excess of 50 MW, under section 36 of the Electricity Act 1989). The current arrangement for determining section 36 applications is to assess applications against the environmental baseline prevailing at the point of determination. Whilst we are always looking at ways we can improve this process, it is an established process and one that has developed over time and is respected by developers.
We have an opportunity to decide how best to use our devolved powers, mainly through Scottish Ministers' role as a consenting authority for large-scale energy infrastructure projects, to create an approach to onshore wind that meets a range of policy objectives:
- climate change and renewable energy targets, including community and locally owned energy targets;
- shared ownership commitment;
- jobs and skills retention; and
- energy security
- protection to residents and the environment
Any actions must be balanced with making Scotland attractive to investors. We want to remain open for business for onshore wind.
New applications, whether for new sites or repowered sites, must take into account the cumulative impact the proposal will have with already existing and consented wind farm developments. In some areas, the cumulative impact of wind farm developments mean that landscapes are unable to accommodate further developments without landscape and visual impacts becoming unacceptable. However, the physical siting of those existing wind farms does not always produce the maximum yield (or maximum contribution to Scotland's renewable energy targets) from the available wind resource in that area, whilst minimising impacts efficiently.
We acknowledge that all sections of society are impacted differently in any planning decision, therefore considering a strategic approach whereby any policy would have wider implications than one determination has been challenging.
Drawing on past experiences across the UK, such as ' TAN 8' in Wales we wish to present a number of options that we have considered some of which we wish to consult on. This follows informal discussion we had with a number of stakeholders during 2016.
The Scottish Government's Land Use Strategy includes Principles for Sustainable Land Use, which should inform land use choices across Scotland. It is useful to reflect on these principles in considering the various options presented The full Land Use Strategy can be found here , with a summary of the key principles outlined below.
The principles are that:
a) Opportunities for land use to deliver multiple benefits should be encouraged.
b) Regulation should continue to protect essential public interests whilst placing as light a burden on businesses as is consistent with achieving its purpose. Incentives should be efficient and cost-effective.
c) Where land is highly suitable for a primary use (for example food production, flood management, water catchment management and carbon storage) this value should be recognised in decision making.
d) Land use decisions should be informed by an understanding of the functioning of the ecosystems which they affect in order to maintain the benefits of the ecosystem services which they provide.
e) Landscape change should be managed positively and sympathetically, considering the implications of change at a scale appropriate to the landscape in question, given that all Scotland's landscapes are important to our sense of identity and to our individual and social wellbeing.
f) Land use decisions should be informed by an understanding of the opportunities and threats brought about by the changing climate. Greenhouse gas emissions associated with land use should be reduced and land should continue to contribute to delivering climate change adaptation and mitigation objectives.
g) Where land has ceased to fulfil a useful function because it is derelict or vacant, this represents a significant loss of economic potential and amenity for the community concerned. It should be a priority to examine options for restoring all such land to economically, socially or environmentally productive uses.
h) Outdoor recreation opportunities and public access to land should be encouraged, along with the provision of accessible green space close to where people live, given their importance for health and wellbeing.
i) People should have opportunities to contribute to debates and decisions about land use and management decisions which affect their lives and their future.
j) Opportunities to broaden our understanding of the links between land use and daily living should be encouraged.
Options for developing a strategic approach
During 2016 the Scottish Government spoke with a large number of stakeholders on creating a strategic approach for onshore wind. There were strong views for and against a strategic approach.
Informed by these discussions, we have set out below options for our approach, with the intention of providing transparency on what has been considered so far:
1. National spatial approach
2. Regional targets
3. Locally co-ordinated approach.
4. Business as usual
We have ruled out the first two approaches for the following reasons:
Option 1. National Spatial approach
This would involve setting a large, national spatial plan for onshore wind, identifying those sites suitable for wind development taking into account wind speeds, environmental constraints and residential amenity.
This approach would be similar to a national version of the local development plans already produced by local authorities except it would also be mapped on suitability of the site to generate electricity, not just capacity to support the development. Areas of national strategic importance for development could be highlighted.
This might allow us to get the maximum capacity from our land whilst minimising cumulative impacts to selected areas.
Reasons for not pursuing
- Our assessment is that it would further complicate and duplicate established practice already set out in spatial frameworks.
- Further work would be required on economic impacts which may for example change land values for land.
Option 2. Regional targets
This would involve setting regional onshore wind targets for local authorities - either as generation targets or installed capacity. This would be similar in concept to the Welsh Technical Advice Note 8 ( TAN 8) where regions were identified as Strategic Search Areas ( SSA) each with a target and it would be for the local authority to undertake refining the detail of each SSA.
A regional target could provide local authorities with some clarity as to what is expected of them. Our renewable resources are perhaps not distributed evenly across the country so it stands to reason that different areas of Scotland will be likely to produce more renewable energy generation than others. We also explored the idea of a renewable installed capacity target rather than restricting it to onshore wind. Any such targets will also need to take into account the risks of cumulative impact and to reflect existing installed capacity.
Reasons for not pursuing
- Regional targets in practice might be viewed as caps.
- Regional targets could duplicate work already implemented by local authorities through the landscape capacity assessments in their local development plans.
- Some areas might consider they contribute more than others which is understandable but it is only to be expected due to resource availability. We need to ensure that onshore wind is developed at the lowest cost, but also taking into account cumulative impact and to prevent unacceptable impacts on residential amenity.
We are therefore seeking your views on options three and four only:
- 'locally co-ordinated approach' scenario; and
- retaining the current consenting process, 'business as usual'.
Option 3: Locally co-ordinated approach
This approach involves fostering more co-ordination by commercial developers.
With commercial interests to protect it is natural for developers to work isolated from their competitors, but there could be scope for the Scottish Government and local authorities to bring developers together to consider the best use of land and energy resources, to share costs where appropriate, and to make the most of infrastructure such as available grid connections.
By sharing assets between users, a coordinated approach has the potential to reduce the cost of delivering individual generation projects as well as providing wider system and policy benefits.
This is not the first time this approach has been considered. The 'Isles Project', a collaboration between governments in Scotland, Ireland and Northern Ireland recommended a similar approach for interconnected grid networks  .
Under this scenario, there might be an informal process at the pre-scoping stage of a consent, whereby developers identified as interested in adjacent or proximate sites within a region would be encouraged to work together to consider the 'best' (as in the most strategically efficient and cost-effective) use of land and energy networks. This approach would focus on gaining the highest capacity whilst minimising the cumulative impact on the environment and residents.
Our Land Use Strategy might be said to underpin such an approach in its emphasis on balancing competing interests; but the Land Use Strategy in fact goes further to encourage all land users to work together to ensure multiple benefits and therefore one industry should not work in isolation from other users. Hence a wider avenue for exploration might be to include other renewables and also heat networks in collective co-ordinated area development discussions. In principle, this might allow developers to take advantage of wider construction and infrastructure works and reduce costs.
Any implementation of this approach would also need to include consultation with host communities.
Option 4: Business as usual
We have an established system for consenting applications for new developments above 50 MW.
It remains an option to continue with the system as it stands. Scotland has been successful in our deployment of onshore wind generation and if our current system works best then we are happy to continue with it whilst being open to less ambitious suggestions on how to improve on it. We welcome views on maintaining the current approach.
4.1 Do you agree or disagree with the proposals to pursue option 3, a 'locally co‑ ordinated approach'? Please provide reasons to support your answer.
4.2 Do you agree or disagree with continuation of the Scottish Government's 'business as usual' approach (option 4)? Please provide reasons to support your answer.
Email: Debbie Kessell
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