(This paper is an additional appendix to be considered alongside CLPG’s previously submitted objection to the planning application for 17 wind turbines on Clatto Hill) 

• The main sources used to compile this appendix are: 
• ·      UK Government’s White Paper, Our Energy Future, February 2003
• ·      SPICe Briefing on Renewable Energy, Graeme Cook and Jim Dewar, December 2003
• ·      Submission from the Scottish Executive to the Enterprise and Culture Committee Inquiry into Renewable Energy, February 2004
• ·      The debate in the Scottish Parliament on Energy on 22 April 2004
• ·      Precognition to the Public Local Inquiry concerning the 3 turbine planning application at Balado Activity Centre, by Geoffrey A. Sinclair, October 2003
• ·      The Scottish Parliament’s Enterprise and Culture Committee Report on Renewable Energy in Scotland
•  

Material Considerations Related to CO2 Emissions and the Scottish Executive Renewables Targets

The purpose of this appendix is to argue that the Scottish Executive’s renewable energy targets do not constitute a material consideration of sufficient weight to warrant a departure from those of Fife Council’s planning policies to which we have drawn attention in the body of our objection.

The UK Government and the Scottish Executive operate policies which reflect their conviction on the need to reduce CO2 emissions.  This need is not contested here. A radical reduction in CO2 omissions would require serious long term extensive effort. The Scottish Executive’s targets do not amount to this. Electricity generation is only one part of a much bigger picture.  Only 20% of our total energy need relates to electricity generation. 40% relates to direct heating and 40% to transport. (source SRF evidence to E&CC).

In contrast with the active promotion of the 18% renewables target, there is NO target related to direct heating using biofuels, solar power and combine heat and power plants.  Nor is there any target related to reducing CO2 in transport although bio-diesel technology exists and some hope is pinned on hydrogen fuel in the future.

Large scale electricity generation from renewables cannot actually come from onshore wind turbines. The first reason for this is because the scale of development would have an enormous impact on Scotland’s landscape.  Several thousand turbines would be required devastating Scotland’s landscape. The second reason is that wind is an unpredictable intermittent source, which needs back up and/or energy storage technologies not currently available, and therefore can only be one source in a varied mix. The larger a proportion of the mix supplied in the form of onshore wind, the more back up generating capacity, and therefore the more expense, required. Although it is both UK Government and Scottish Executive policy that a mix is required, they anticipate the short term target of 18% in Scotland will come mainly from onshore wind.  Onshore wind generating capacity much beyond that figure would require stand-by back up and/or storage mechanisms, at considerable extra expense.

Wave and tide sources are not yet available in commercial form, but it is recognised that when they are, they can contribute on a much larger scale. Although wave energy is intermittent, it is more predictable. Tide offers the best prospect for reliable supply, least hindered by intermittency. The Scottish Executive recognises the need to accelerate the process of commercialising these forms of energy generation.  FREDS (The Forum for Renewable Energy Development in Scotland) has been charged with bringing forward a plan to do this, which it expected to do during the summer of 2004. In European terms, Scotland has a research and development lead in marine energy technology as well as the best marine energy resources round its coasts.

 

Onshore wind is being encouraged as a short term measure just now because:

• The technology is available in commercial form, and

• Benefits are seen to accrue to the Scottish Economy.

• The mechanisms used are price mechanisms, which relate only to the direct costs of wind turbine generation. The costs in landscape disfigurement are not reckoned with.  The planning system is left to protect the landscape where it can.

 

There are three sources of evidence suggesting that the 18% target is on course to be met. 

 

One is considerations of output in calculations done by Geoffrey Sinclair, in his precognition for the Balado Public Inquiry.  An extract from the precognition is appended. This evidence amounts to a calculation of output expected from proposals for wind farms which are either recently built or have planning consent which almost reaches the Scottish Renewables target, before taking account of proposals which have not been determined and which total 183% of the additional capacity required for the target.  In other words, the power companies have brought forward proposals very considerably in excess of the 2010 target.

 

The second source of evidence is the Scottish Executive’s consideration of generating capacity required to reach the 18% target. The following figures are given in the Scottish Executive’s written evidence to the Scottish Parliament’s E&CC Inquiry into renewable energy currently in progress.

 

The Scottish Executive reckons about 1000 MW additional generating capacity is required.  It notes that the following can contribute to this:

•  400 MW Section 36 consents given in 2003
• 1,300 MW within current Section 36 processes
• 3,000 MW at scoping stage
• 1,708 MW smaller scale local planning applications listed in a table.

 Only a modest fraction of this capacity has to be realised to meet the 1000 MW estimate. The same evidence to the E&CC describes a proposal for a 1,000 MW windfarm based on the Beatrice Oilfield in the inner Moray Firth.

 

The third source of evidence is the bluntly stated conclusion of the Enterprise and Culture Committee Report on Renewable Energy in Scotland, paragraph 10. This states, “It is clear from the evidence the Committee has taken that the Executive will meet its short term target of 18% of electricity from renewable sources by 2010.”

 

The pressure for onshore wind power stations and the consequent surfeit of proposals seem to come from a large number of companies seeing financial benefit to themselves. In a debate CLPG members attended in Edinburgh earlier this year, a representative from one of the power companies (not Scottish Power) stated that the only people the power companies hate more than the planners are other power companies.  Unwittingly, this put the current dash for wind in a clearer perspective for us. 

Of course it could be argued that it would be better to beat rather than just meet the 10% target for 2010. However, opposition exists to many more onshore windfarms than just Clatto Hill. Opposition arises primarily due to an anticipated severe adverse impact on Scotland’s attractive landscapes, amenity and health considerations for people living nearby and adverse wildlife impacts. 

If a longer term radical reduction in CO2 emissions from electricity generation is to materialise, without recourse to new nuclear power plant, forms of generation other wind would be essential. Accelerating the commercialisation of wave and tide power and giving this a chance to come though as major contributors, as the Scottish Executive wants to do surely avoids the need to disfigure valued Scottish landscapes in the way that the short term “dash for wind” is threatening to do?  While the Scottish Executive states a wish to meet targets from a range of renewable technologies, the reality is that its main policy instrument only produces wind power, to the neglect of other possibilities.  The Enterprise and Culture Committee has identified this problem in its report.  In paragraph 15 of its Report, it states, “By focusing power companies’ attention on wind, it may even have hindered the commercialisation of other renewable technologies.”

 

Nothing in the Scottish Executive’s promotion of renewable energy requires the disfigurement of Scotland’s landscape. A debate in the Scottish Parliament as recently as 22 April was summed up by the Deputy Minister for Enterprise and Life Long Learning, Lewis Macdonald MSP. Some quotes from his speech are:

 “… we must support the development of a range of renewables technologies if we are to meet the ambitious targets we have set. 

“It is entirely false to suggest that we are ignoring the contribution that technologies other than wind power can make. 

“We favour the use of as wide a range of renewable and associated technologies as possible. 

“… planning guidelines are in place to protect the environment and communities’ interests, which will result in inappropriate and inadequate applications being thrown out. 

“If a planning issue exists, it concerns ensuring that planning guidelines are up to date, that they reflect our objectives and that they achieve the balanced judgements that have been described.

 

In short, the Scottish Executive does not expect planning policies designed to protect and enhance the landscape and to protect neighbours from unsatisfactory proposals to be overturned. The figures on activity to meet the 2010 target demonstrates that there are many more schemes than required. 

We want to remind the Council that its Structure Plan was approved by the Scottish Executive AFTER the Renewables Obligation (Scotland) 2002 came into being.  We can surely assume, therefore, that there was nothing in that Structure Plan which the Scottish Executive felt inappropriate in light of that Obligation. 

Notwithstanding the Minister’s words in April 2004, the Enterprise and Culture Committee makes the forceful charge that, “The Executive’s current renewables policy is unintentionally working against the development of renewable sources other than onshore wind.”  The Committee goes on to underline that this is “not good energy policy” and also makes a strong case for the economic benefits to Scotland of capitalising on its current knowledge to become a leader in the development of marine renewable energies.  Paragraph 49 of its Report states, “The Committee believes that the opportunities and potential benefits presented by the renewables energy sector are so great that the Executive should be prepared to invest significantly in the sector.”

 If the sense of this Committee’s findings is followed, longer term targets for renewable energy will be addressed mainly by means other than onshore wind. 

CLPG hopes that councillors will study the Enterprise and Culture Committee Report in full.  If they do so, it will become doubly clear that the wind farm proposal for Clatto Hill is an irrelevance to the real effort required to reduce CO2 ommisions.

EXTRACT FROM GEOFFREY A SINCLAIR’S PRECOGNITION TO THE BALADO PUBLIC ENQUIRY 

The Scottish Renewables Target

 

5.2.1    The Scottish Renewables Obligation anticipates an increase in the proportion of renewable energy from the present 12% to 18% by 2010. The present level, 33TWh p.a,. is due mainly to existing hydro schemes. UK demand has increased at 2 – 3% p.a but forecasts have assumed that this will drastically reduce to as little as 2.4% overall by 2010, due to the effect of measures to conserve energy. This appears unrealistically optimistic, but even if the historic annual increase-rate were to be reduced to an average of 1% per annum over the period to 2010 the Scottish consumption in that year would be 36.1TWh. The forecast increment of 6% in the supply of all forms of renewable supply would thus require an additional 2.54TWh p.a by that time, calculated as 18% of 36.1 TWh  = 6.5 TWh p.a  minus  12% of 33TWh p.a = 3.96 TWh p.a.. 

5.2.2    The Balado turbines would provide 0.0158TWh p.a, approximately 0.4% of the additional average annual output required, as shown above. It follows that around 250 such installations would be required to reach the target.

5.2.3      It is therefore instructive to look at the contribution which known on-shore wind energy sources are anticipated to make to that 2010 annual target, so that the proposal can be seen in a realistic renewable energy context. The material attached as Appendix I is restricted to a)  projects which have been recently constructed and which are not likely to figure in the 12% base-line calculations; b) those which have planning consent but are not yet constructed  and c) those which are known to be within the planning or development process. The list has been compiled from various sources, including the Scottish Executive, SNH, and the BWEA, and is known to be both incomplete and an under-estimate. For example, the installed capacity of many of the major schemes detailed has been raised by the adoption of larger capacity turbines.  It is also important to remember that by definition this ignores the increasing role of other renewables, all of which are likely to have an additional part to play in reaching the target, as explained in Section 2, above..  

5.2.4  The schedule in Appendix I shows that the 7 most recently completed  installations account for 10.3% of the increment required and those with planning consent constitute a further 70.9%. This means that almost the whole of the Scottish Renewables Obligation target for 2010 is accounted for by built and consented wind power projects. Moreover, known projects under development account for a further 183%. Since these exclude several recently publicised schemes, it can be said that existing permitted and built projects, plus those in or near the planning process represent around three times the increment required from wind power sources alone, irrespective of contributions from other renewables and further projects of all types anticipated during the forthcoming years. It follows that if this project were excluded from this, there would be no appreciable effect on the target in view of all the other projects available.