Select Committee on Environmental Audit Appendices to the Minutes of Evidence


Memorandum from EcoGen Developments Ltd


  1.1  EcoGen Developments Limited is a group of small renewable energy companies based in Machynlleth, Wales. EcoGen has played an important role in wind energy development since the onset of onshore windfarms in the early 1990s. EcoGen is currently involved in eight onshore projects in England and Wales, having previously developed windfarms for major companies including PowerGen, Scottish Power and Tomen Power.

  1.2  EcoGen welcomes the recommendations of the Performance and Innovation Unit's Review and in particular, their commitment to the commercial development of renewable energy sources. This evidence does however draw the Committee's attention to a worrying constraint on windfarm development in the UK, which EcoGen believes could undermine the achievement of government renewable targets. This constraint lies in MoD's ability to object to windfarm development across large areas of the country without appropriate scrutiny or compromise.


  2.1  The PIU Review reinforces the Government's target of 10 per cent of electricity generated by renewables by 2010. It also recommends an additional target of 20 per cent by 2020. EcoGen believes that the continued development of onshore wind power will be essential to the realisation of these targets for the following reasons:

    (i)  Many of the new generation renewable technologies in which the Government has started to invest (offshore wind, solar, energy crops) are still at the development stage. The PIU Review recognises this problem and states that their feasible rate of deployment will be "the main technical consideration for the increased use of renewable energy." Although the Prime Minister has indicated that they will each play a role in achieving the 2010 target, the precise level of their contributions remains uncertain.

    (ii)  Onshore wind generation is the most commercially and technologically advanced of the new renewable energy types. If government targets are to be met, there will therefore have to be considerable reliance in the short term, on electricity generation from this source. This is admitted in the PIU Review, which states that in order to meet the 2020 target, "build rates for the leading options would need to be at levels never before seen in the UK. Onshore and offshore wind would need to be installed at a rate of between 1-2 GW per year in the period 2010-20." This is indeed a substantial aim, given that to date the total figure since 1991 stands at around 400 MW.

    (iii)  The Review predicts that onshore wind will provide the cheapest electricity by 2020 at a rate of 1.5-2.5 p/kWh. This implies that by 2020, onshore wind will still be the most commercially advanced and most amenable form of renewable electricity supply.

  2.2  Onshore wind resources in the UK are still relatively under exploited. The UK has 40 per cent of Europe's onshore wind resources and yet it has reached only 0.38 per cent of electricity generated by wind power (offshore wind contribution to this figure is negligible).

  2.3  It has been widely suggested that the Government will need to employ a more radical approach to its renewables strategy, if it is going to meet its 2010 and 2020 targets. The tentative nature of the Government's policy to date has been a cause of concern for external organisations campaigning on the renewables issue.


  3.1  In EcoGen's experience, a significant constraint on the expansion of the renewables programme in general, and onshore wind in particular, is MoD's frequent objections to the development of windfarms. The Environmental Audit Committee touched upon this problem briefly in its renewable energy inquiry pre-General Election 2001. The issue has also been the subject of many questions within Parliament over recent months.

  3.2  MoD effectively has the ability to object to windfarm developments on all designated MoD low-flying zones in the country. As a map detailing these areas would show, most of the UK is covered by various military radar zones which require that MoD be consulted on any proposed windfarm development. This consultation process becomes more serious in tactical training areas, where MoD has shown that it is regularly willing to object formally to the siting of wind turbines. Indeed, one of the Environmental Audit Committee's own members, Simon Thomas MP, expressed interest in the frequency of MoD's objections in a written parliamentary question to the Secretary of State for Defence in December 2001. The response stated that "Over the last two years, the Ministry of Defence has objected to 26 proposals to site windfarms within the tactical training areas." EcoGen would be willing to liaise with those developers whose applications have attracted objections from MoD and collate this information for the Committee, if deemed appropriate at a later date.

  3.3  Analysis of wind distribution in the UK confirms that the implications of the MoD's position for the Government's renewable energy targets and future onshore windfarm applications could prove to be significant. A wind distribution map of the UK would clearly show that the ideal area for the siting of large-scale windfarms is that covering North-West England and Scotland. However, once existing exclusion zones (tactical training areas, areas of outstanding natural beauty, national parks and urban areas) are superimposed onto this area, little prime location land is left from which to choose a suitable windfarm site. In any case, such concentration of future development would inevitably be open to local opposition.

  3.4  In EcoGen's experience, MoD's stance vis-a"-vis a particular windfarm development allows for little, if any, discussions or compromise with other interested parties such as DTI or the windfarm developers themselves. A specific example is the proposal to develop an 80 MW windfarm in Kielder Forest, Northumberland. Following objections from MoD, the Secretary of State for Trade and Industry, on 29 March 2001, decided to deny its application without a public inquiry.

  3.5  In this instance, MoD objections arose due to the proposed windfarm's proximity to RAF Spadedam Electronic Warfare Tactics Range. It believed that wind turbines would interfere with radar and low-flying aircraft. EcoGen sought to allay these fears by commissioning its own expert research, which found that the objections and resulting veto were unjustified. It found, for example, that low flying training tends to focus on the use of valleys for "Terrain Screening", whereas wind energy utilises the more exposed higher land.

  3.6  The decision to deny permission for a windfarm at Kielder is particularly damaging to the development of onshore wind power and the confidence of wind power developers and investors in the UK because:

    (i)  The windfarm would be the UK's largest, adding 70 per cent to England's current wind power;

    (ii)  It is based in a prime wind location;

    (iii)  It has universal support from the local population;

    (iv)  The RAF initially did not raise objection to the proposal. Money was therefore invested in the project (for example in the preparation of the Environmental Impact Assessment) at the developer's expense.

  3.7  MoD's objections are indeed a cause for concern, particularly as installed wind power is doubling worldwide every two years. The following issues should be considered:

    (i)  In countries like the US, Germany, Spain and Denmark wind power has been developed to a much higher concentration without compromising defence systems. Spain, for example, is even proposing to fuel some of their airports through nearby turbines.

    (ii)  British pilots will come into contact with obstacles such as turbines in real-life defence and attack situations.

  3.8  All Government Departments, including the MoD, are now signed up to a target of ensuring that, by 31 March 2003, at least 5 per cent of their electricity comes from renewable sources that are exempt from the climate change levy, or from self generation, provided this does not entail excessive cost, rising to at least 10 per cent supply from such sources by 31 March 2008. As the MoD uses around 80 per cent of all government consumption, progress by MoD will obviously be vital in ensuring that the Government meets its target overall. The Kielder project is on the doorstep of MoD establishments consuming significant quantities of electricity and could contribute significantly to meeting its renewable energy targets. The target for MoD has been agreed since their memorandum to the Committee of March 2001, when they stated that "at present MoD does not have targets for the purchase or self-generation of renewable energy for the period up to 2010" (Appendix 30, Memoranda to the Environmental Audit Committee Inquiry into Renewable Energy, 10 May 2001).

  3.9  The Government has recognised that there is a problem between MoD and its renewable agenda. Qinetiq is currently producing a DTI-sponsored report into the effects of wind turbines on radar which is due for completion in September 2002.


  4.1  MoD's concerns about the wind turbine development fall into two categories:

    (i)  The physical danger to pilots engaged in low flying training.

    (ii)  Possible interference with both its primary radar and secondary surveillance radar technology.

  4.2  EcoGen recognises the importance of both these concerns and works with MoD, wherever possible, to overcome them. The location of the turbines clearly needs to be sensitive to safety concerns. As for radar interference, EcoGen's own research and the experience at RAF Culdrose in Cornwall show that this problem is not as serious as MoD claims.

  4.3  MoD has to train its pilots to deal with the actualities of 21st century warfare. Increasing numbers of physical obstacles such as wind turbines are a reality of the modern world. EcoGen has been in discussion with MoD about the possibility of the Kielder windfarm being incorporated into the pilot training programme and being used as a military asset. Unless such a compromise can be agreed, the future for other large-scale onshore wind applications remains uncertain.


  Renewables are going to be a large part of the Government's energy agenda. To meet its targets however, the Government has to show commitment to the development of onshore wind power. At present, the onshore industry and its investors face uncertainty as MoD has the power to object to proposals in all designated low-flying zones. This power has been shown to dictate DTI's decision to deny permission to a windfarm development. MoD must be willing to consider compromises which will allow the Government to achieve its renewable energy targets whilst enhancing the quality of military air training.

March 2002

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