Select Committee on Environmental Audit Memoranda


Memorandum from Scottish Natural Heritage

  All forms of electricity generation have some impact on the environment. Renewable sources avoid the chemical and physical affects of fossil and nuclear fuels, but have the capacity to affect aspects of the natural heritage (Annex 1). There is a risk that the development of renewables could obscure the need for the fundamental changes which will be required in the pattern of energy consumption, in order not only to meet the Kyoto emission obligations but to attain the higher and more stringent reduction targets which are likely to follow. Developing renewable energy could be used as a means of soaking up new energy demand without reducing existing fossil fuel consumption. Current DTI projections of energy use are for continued growth of around 0.5 per cent per annum. The top priority in energy policy should therefore be to encourage energy needs to be reduced, through efficiency measures and better use of waste heat, to reverse this trend for continued growth. We support the development of renewable energy as an integral part of the Government's Climate Change Programme; and support the Government's stated commitment to achieving the majority of the emissions reductions through energy conservation/reductions in demand.

  SNH recognises the importance of addressing the issues of climate change, and the contribution which renewable energy can make towards that programme. Renewable energy development can also contribute to wider sustainability objectives, including rural employment. SNH therefore supports the development of renewable energy sources as a replacement for energy produced from fossil fuels. However, renewable energy developments have the capability of causing significant adverse impacts on landscapes, habitats and individual species. A priority for renewables policy should be to foster kinds of energy technology, and approaches to their adoption, which are most likely to be consistent with overall natural heritage objectives. In supporting the development of renewables, SNH recognises that some change to some of Scotland's landscapes may be unavoidable.

  We seek a strategic approach in which renewable energy development is guided towards the locations and the technologies most easily accommodated within Scotland's landscapes and habitats without adverse impact, and which safeguard elements of the natural heritage which are nationally and internationally important.

  One important element of the approach we seek should be that much less emphasis should be placed on securing renewable energy at least cost. SNH considers that the principle should be that greenhouse gas emissions need to be reduced without diminishing the overall quality of life, and this should include protecting the high quality of the Scottish environment. The price of services to consumers should not be driven down if in so doing environmental costs are incurred.


  SNH sees it as the role of the planning framework to provide a basis for ensuring that renewable energy is developed with due attention to limiting potential impacts on the natural heritage and safeguarding areas deemed worthy of special protection. If these aims are to be compatible with Government's current targets for renewable energy, strong planning guidance will be required. We would like to stress that the role of the planning system becomes even more critical with the move to the new basis for subsidising renewables output.

  A strategic approach should be adopted to ensure that renewables development is guided towards those areas, technologies and types of development which have the least adverse environmental impact.


  In the longer term it is likely to become necessary to increase the proportion of generation from renewable sources above current targets, so as to continue to reduce emissions of carbon dioxide. This will become even more necessary if Government decides not to replace Scotland's nuclear capacity. Strategic decisions about which should be the preferred renewable technologies to meet future energy needs, and how to encourage these, should take full account of their impacts upon the natural heritage. The visual impact of large-scale renewable generation means that future bulk electricity supply is likely to be served best by encouraging at least a proportion of such generation to take place offshore.

Short to medium-term

  In the short-medium term, in view of the potential for technologies which are currently close-to-market to have adverse impacts on landscapes and habitats, SNH considers that meeting energy needs requires a strong strategic planning framework to ensure that development is well-structured, with technology types and development proposals guided towards areas which are able to accept them with least impact on natural heritage quality. Current generation targets could be met through a great variety of development options in terms of the size, number, and spatial distribution of individual components. A strategic approach is likely to require appropriate action at national level to direct development towards locations where overall impacts are likely to be least, and at local level to direct development towards appropriate siting and design.

  The following general principles inform SNH's views on proposals for renewables development:

    —  to accommodate future renewable energy generation on the scale required to help in addressing climate change, some change to some of Scotland's landscapes is likely to be unavoidable. Development of a scale (individually or cumulatively) that changes landscape character is likely to be preferred where the landscape is already developed or visually man-modified, and relatively close to centres of population. Areas which are highly valued for recreation and amenity should however be safeguarded;

    —  we should seek to safeguard the qualities of areas where natural heritage value is associated with low evidence of human intervention;

    —  over the remaining area of Scotland, renewable energy developments should be accommodated (individually or cumulatively) without significant adverse impact on the character of the landscapes into which they are placed or the natural heritage value for which these areas are appreciated;

    —  SNH has encouraged exploration of one or more locations for very large windfarms, substantially larger than developed to date, to help meet a significant proportion of Government's renewable energy targets in Scotland. Such sites should be within or relatively close to the Central Belt or major populations centres;

    —  particuarly in more populated parts of the country, there may be pressure to locate renewable developments in areas which are out of sight. This could displace developments towards areas where natural heritage values depend upon low human impact. The need to minimise overall natural heritage impact may lead to resisting such displacement where it is likely to lead to natural heritage impacts being greater than otherwise necessary;

    —  the impacts from new renewables developments derive not only from the generating technology, but also from the track infrastructure required to service them. SNH has encouraged exploration of opportunities to place new developments in areas where a track infrastructure already exists, eg in forestry; and

    —  SNH encourages exploration of the natural heritage impacts of offshore renewable development. Outwith areas of high value for marine wildlife, SNH expects the overall impacts on the natural heritage to be lower when renewables developments are situated offshore. SNH supports strategic exploration for appropriate locations and the promotion of appropriate technologies.

January 2001

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