Additional support for island renewables

Transcription

1 Additional support for island renewables RSPB Scotland response to the DECC consultation October 2013 RSPB Scotland s position on wind energy The RSPB views climate change as the most serious long-term threat to wildlife in the UK and globally. If we are to avert serious disruption to natural, social and economic systems, we need to act now to limit the use of fossil fuels that release greenhouse gases into the atmosphere. We therefore support the increased use of wind power, as part of a mix of renewable energy technologies, as long as wind farms are sited, designed and managed so they do not significantly harm birds and other wildlife or their habitats. 1. Do you agree with the analysis in Baringa/TNEI report and other sources quoted in this consultation and the conclusions drawn from it? Please provide evidence to support your answer. We have some concerns about the methods for estimating the wind resource potential for the islands in the Baringa/TNEI report. The report purports to present the estimated total practical resource for onshore wind energy on the Scottish islands, defined as the total resource after taking into account realistic locations, cost of energy as well as locational and environmental constraints. It is unclear, however, that environmental constraints have in fact been taken into account or factored in appropriately. Figures given for Orkney and Shetland are based on the maximum figure found in available studies, whereas the figure of 550 MW presented for the Western Isles is an assumption that is described in the footnote as being based on planning data. No information is provided about how planning data was used to produce this figure, so it is not possible to assess whether any environmental constraints have been taken into account, for example by applying a sufficiently conservative consenting rate or undertaking spatial analysis of available sites for wind energy. The figures presented for Orkney and Shetland of a maximum resource potential of 900 GWh/yr and 7 TWh/yr respectively, are derived from a report by Aquatera in The figures selected are taken from the maximum estimate in the report, which is based on a lower acceptability scenario, meaning it includes anything deemed to have more than a 20% likelihood of gaining planning approval. In other words, the estimate includes all potential developments that, due to planning constraints including any environmental issues, only have a 1 in 5 chance of being approved. This scenario is not realistic given our experience of the planning constraints related to environmental sensitivities in these areas (detailed further below). It is disappointing that the report, published in May 2013, did not make any attempt to factor in consenting rates and increased understanding of planning constraints and environmental sensitivities for onshore 1 Available at:

2 wind since these figures were published in 2005, and simply opts to adopt the maximum available figure from the range of available studies. Any assessment of the generation potential from the Scottish Islands must recognise that there are significant planning constraints in these areas because of their importance as areas for wildlife and large amount of land protected under various national and European designations. As the figures in the Baringa/TNEI do not factor in these environmental sensitivities satisfactorily, caution must be exercised in how the figures are used to inform the creation of any targets or incentives for development. In particular, there can be no assumption that these levels of onshore wind deployment can be achieved at low or minimal environmental impact. 2. Do you agree with our proposal to provide additional support to projects located on the remote Scottish islands where such a project meets the objectives in paragraph 1.21 and have all of the characteristics described in paragraph 1.25? RSPB Scotland supports renewables development in the right places. However, it is difficult to take a firm position on the specific strike price proposed, as it is not clear that environmental sensitivities were taken into account in developing the proposed strike price, or how it will be ensured that only sites with minimal environmental impact will be eligible to receive it. The Scottish islands support exceptional nature conservation interests, including unique and important habitats for wildlife including important national populations of birds. This is reflected in the large number and extent of sites designated under the EU Birds and Habitats Directives. The scale of designations in the Western Isles alone underlines the high quality of the environment, with 53 Sites of Special Scientific Interest (SSSI), 15 Special Protection Areas (SPA), 14 Special Areas of Conservation (SAC), 4 National Nature Reserves (NNR) and multiple Ramsar designations for Wetlands of International Importance. Increased incentives are likely to result in more interest in, and applications for large-scale onshore wind developments in sensitive areas, and increased pressure on wildlife sites including sites protected under European law. Whilst RSPB Scotland recognises the potential for climate and socioeconomic benefits from renewables development on the islands, it is crucial that due consideration is given to the potential environmental impacts of significantly increasing incentives for development in sensitive areas. If the proposed strike price goes ahead, it will be vital that the planning system responds appropriately and there is not undue pressure to consent damaging developments, or inappropriate expansions to existing sites. There will be a need to carefully assess proposals, including their cumulative impacts, to ensure they do not harm the environment. RSPB Scotland strongly recommends that impacts of strike prices on the environment are reviewed on an ongoing basis, for example as part of any wider review of the impact of the Contracts for Difference regime. This will be important to ensure any perverse outcomes of additional subsidies are identified and the system updated accordingly and in a timely manner. A good example illustrating the importance of assessing fiscal regimes for their environmental impact is the case of tax incentives resulting in inappropriate plantation forestry in the flow country. Tax incentives in the 1970s and 1980s encouraged plantation forestry to be inappropriately sited on important peatland habitat. The impact of these incentives, despite being introduced in good faith, has been a large scale loss of ecosystem services, including

3 damaging vital storage of carbon in peatland. The consequence of these incentives, which were abolished in 1988, has been years of work and massive funding inputs from government to reverse their impacts, by removing the plantations and restoring the affected habitats, work that is still ongoing today. This could have been avoided through a thorough upfront assessment and ongoing monitoring of the environmental impacts of the incentives. 3. Do you agree that the Scottish islands comprising the local government areas of Comhairle nan Eilean Siar, Orkney Islands Council, and Shetland Islands Council are unique in being able to develop projects which have all of the characteristics described in paragraph 1.25? Do potential projects on the Scottish Islands have other relevant unique characteristics which warrant additional support? The consultation document states in paragraph 1.25 that there are a number of ideal sites which allow for very large scale developments with minimal environmental impact. Whilst we recognise there are a limited number of sites on the Scottish Islands where large onshore wind development can be accommodated with appropriate monitoring and mitigation, the planning constraint imposed on wind energy in these areas due to environmental sensitivities should not be underestimated. This is currently not reflected in the consultation document, which focuses on challenges posed due to lack of financing, grid access and supply chain, citing these as the key challenges without reference to environmental constraints. RSPB Scotland believes that it is unlikely that there is scope for further large onshore wind development on the Scottish Islands, without resulting in significant environmental impacts. Whilst we have by no means objected to every application, we are concerned by a number of inappropriate onshore wind applications that have come forward in the islands which risk significant wildlife impacts. In 2012, Scottish and Southern Energy withdrew its application and dropped its interest in the Pairc Wind Farm, citing predicted bird collision risk as the reason. In 2008, the decision was finally made to reject the application for 234 wind turbines on the Lewis Peatlands SPA, which according to the Environmental Statement would have resulted in the loss of at least 50 golden eagles and disturbed up to 6255 ha of active blanket bog an internationally rare habitat, amongst several other significant impacts. Several projects have been forced to scale back their plans in order to reduce anticipated impacts, and cumulative impacts are likely to be an increasing issue for new proposals, particularly those of larger scale. We emphasised when we withdrew our objection to the Stornoway Wind Farm in 2012, for example, that this will be a challenging site for the developer (Lewis Wind Power), and the consent for 36 turbines on this site will have significant implications for assessing the cumulative impacts of further wind energy development on Lewis. It can certainly not be described as an ideal site. DECC must also be mindful that inappropriate onshore wind developments on the Scottish islands could result in breaches of the EU Habitats and Birds Directives, which may lead to infringement proceedings against the UK Government. In September this year, the Scottish Government was successfully taken to judicial review 2 in relation to their decision to consent the 2 NB/ Currently subject to appeal

4 103-turbine Viking wind farm in Shetland, and found to have failed to fulfil their obligations under the Wild Birds Directive Ministers were found not to have taken proper account of anticipated impacts on breeding whimbrel, a declining species in the UK with approximately 95% of 290 breeding pairs in Shetland. It should be noted that the 2009 Scottish Government commissioned Economic and Community Benefit Study carried out for the Western Isles found there to be significant planning constraint on development, which relates primarily to ensuring that development options are consistent with conservation obligations, and stressed that taking forward renewable energy... has to be done in the context of ensuring compatibility with the varied and rich environmental qualities of the area... underlined by the substantial proportion of the islands land area that is part of the Natura 2000 network 3. It is worth noting also that SHETL s needs case report for a Western Isles HVDC link states that an element of the potential 271 MW of forthcoming applications will be unsuccessful in securing consent...due to the consenting, environmental, commercial and economic risks that the developers will need to consider. 4 Paragraph 1.30 of the consultation document states that DECC propose to provide additional support for renewable projects on remote islands which can (a) achieve the Government s objectives in paragraph 1.21, and (b) have the characteristics described in paragraph For example, an onshore wind project which can be located in an ideal location, operate at a high load factor and is subject to high transmission costs. Whilst the suggestion that the provision of support will be subject to a project having minimal environmental impact is very welcome, it is unclear what is meant here. It is implied that not every onshore wind project on the islands would automatically receive support unless they demonstrate they meet the additional criteria set out in paragraph However, the statement that there are a number of ideal sites, implies that those sites are already known, but are not specified. It is difficult to comment therefore without any information on which sites are being referenced, and if they are taken to include all sites that have existing planning consent. We do not consider that all onshore wind developments with planning consent on the Scottish Islands are likely to have minimal environmental impact. For example, we maintained an objection to the consented Eisgein site on Lewis, and it s proposed extension, as we believe it is likely to have an unacceptable impact on important bird populations especially on one of Europe's densest breeding populations of golden eagle. We are particularly concerned that there is no comprehensive evaluation of the cumulative impacts of the various wind farms proposed and consented on the Western Isles. We would therefore seek clarification from DECC on how minimal environmental impact will be defined in terms of eligibility to access the strike price, given some consented sites in our view already do not meet this criteria. 4. Do you agree with our proposal that additional support should be limited to onshore wind projects, and that the level of support should not exceed that available for offshore wind? In this context how do you consider pre-commercial technologies such as wave and tidal stream should be treated? Please provide evidence to support your answer. 3 Available at 4 Available at: edscasestakeholdersummary.pdf

5 RSPB Scotland supports a diverse, low carbon energy mix, and in the medium and longer term we hope to see successful commercial-scale deployment of wave and tidal renewables in an environmentally sensitive way, in particular given this may reduce pressure on sensitive onshore areas. As such we welcome the statement that additional incentives for marine renewables on the Scottish Islands will be considered, however we are unclear about the reasons for delaying this until the second delivery phase. Given the differences in costs of deployment of onshore wind on the islands were considered to justify a separate strike price, it is unclear why a single strike price is considered appropriate for marine renewables, particularly given the resource potential thought to exist off the Scottish Islands. We would be concerned if opportunities for progress with environmentally sensitive deployment of marine renewables were hampered as a result of this. However, any additional incentives provided to marine renewables should, in the same way as for onshore wind, be subject to the same robust consideration of environmental impacts. 5. Do you agree that the appropriate vehicle for providing additional support for onshore wind on the Scottish islands (comprising the local government areas of Comhairle nan Eilean Siar, Orkney Islands Council, and Shetland Islands Council) is by a specific CFD strike price within the first EMR delivery plan? No comment. 6. Do you agree with the proposal to provide a strike price for island onshore wind projects having the characteristics, described in paragraph 1.25, of 115 per MWh beginning in 2017/18, compared with per MWh for onshore wind elsewhere in the UK? Please provide evidence to support your answer. No comment. 7. Do you agree that we should not provide additional support for wave and tidal within the first delivery plan? Do you agree that the need for and levels of additional support for marine energy should be considered as part of the second EMR delivery plan (subject to progress towards early-commercial deployment)? See answer to question 4. For more information please contact Alexa Morrison, Conservation Policy Officer RSPB Scotland, 2 Lochside View, Edinburgh Park, Edinburgh EH12 9DH Tel: Alexa.Morrison@rspb.org.uk The Royal Society for the Protection of Birds (RSPB) is a registered charity: England and Wales no , Scotland no. SC RSPB Scotland is part of the Royal Society for the Protection of Birds, the UK-wide charity which speaks out for birds