Memorandum from Scottish Natural Heritage
Thank you for your letter dated 3 December,
inviting Scottish Natural Heritage (SNH) to supplement our previous
submissions and/or provide additional information to the above
Renewable Energy Review undertaken by the Cabinet Office Policy
and Innovation Unit.
SNH is a non-departmental public body, sponsored
by the Scottish Executive, responsible for promoting conservation,
enhancement, enjoyment and understanding of the natural heritage.
The Minister for Environment and Rural Affairs in Scotland appoints
the members on SNH's Board.
SNH has contact with the energy industry through
our role in advising on the environmental impact of national policy,
development plans and development proposals. We advise planning
authorities and the Scottish Executive on matters which have a
potential to impact on the natural heritage, and we are a statutory
consultee in relation to proposals affecting sites of national
or international conservation importance, and proposals with Environmental
SNH previously responded to the Environmental
Audit Committee Renewable Energy Inquiry in February 2001 (copy
attached). Around the same time, we published our Policy Statement
1/2 on Renewable Energy. A copy of this policy (which was re-confirmed
by SNH's Board in February 2002) is attached and we ask that it
be taken into consideration during your deliberations.
SNH recognises the importance of addressing
the issues of climate change, and the contribution which renewable
energy can make towards that programme. Provided that a first
priority is given to energy efficiency and demand reduction measures.
SNH STRONGLY SUPPORTS
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 those kinds of energy technology, and approaches
to their adoption, which are most likely to be consistent with
overall natural heritage objectives. While we are supportive in
principle of the expansion of renewables, most forms of renewable
energy development impact in one way or another upon the natural
heritage and there is therefore a need to seek locations and designs
in which environmental impacts are kept to a minimum. We strongly
encourage a strategic approach in which renewable energy development
is guided towards the locations and technologies most easily accommodated
within Scotland's landscapes and habitats without adverse impact,
and which safeguards that which is nationally or internationally
important. In supporting the development of renewables, SNH recognises
that change to some of Scotland's landscapes may be unavoidable.
PIU ENERGY REVIEW
The Cabinet Office Policy and Innovation Unit
Energy Review is a wide ranging report examining the key long
term challenges and opportunities for energy policy in the UK.
SNH contributed to the Review in September 2001, and we are pleased
to note that many of the issues and themes identified in our consultation
response have been considered by the Review.
We particularly welcome the recognition that
the conventional objectives of security of supply and economic
competitivity should be integrated with, and indeed, where necessary,
be secondary to, environmental objectives. We consider that in
recent decades, environmental objectives have not been sufficiently
to the fore in an energy policy, which has been driven by economic
objectives, security of supply, and market liberalisation.
SNH is supportive of the main conclusions of
the Report, in particular:
that the overriding aim should be
to achieve an environmentally sustainable energy system;
the need to make large carbon emission
reductions over the next century;
the priority to be attached to improvements
in energy efficiency and vehicle efficiency;
expanding the role of renewables;
including increasing the target for the proportion of electricity
generated from renewable sources to 20 per cent by 2020; and
the use of economic instruments to
bring home the cost of carbon emissions to all energy users.
More detailed comments with regard to these
points are found below.
The PIU Review concludes that there will be
a strong likelihood the UK will need to make very large carbon
emissions reductions over the next century with energy policy
being the main means of achieving this. From a natural heritage
standpoint, SNH endorses the crucial importance of mitigating
climate change. In addition to the social and economic consequences
of climate change around the globe, climate change is likely to
have very significant impacts on the natural heritage in Scotland,
affecting coastal and montane habitats and including the predicted
loss of certain species and the alteration of characteristic habitats.
We have therefore supported polices on renewable
energy to enable the UK to meet Kyoto targets for 2010, and will
support the development of appropriate new policies, which seek
to pursue the recommendations of the Royal Commission on Environmental
Pollution and implement the sixth Environmental Action Programme
on reduction of greenhouse gases by the year 2050. We therefore
welcome the inclusion of environmental objectives within energy
policy, and in particular the recommendation that where energy
policy decisions involve trade-offs between environmental and
other objectives, then environmental objectives should take precedence,
particularly if there is a risk of failing to meet internationally
agreed emissions targets.
Effective protection of the environment is identified
as a high level objective of Government (Par. 3.9). While tackling
climate change is most prominent, the Report also identifies the
need to safeguard individuals against poor air quality and toxic
chemicals, improve water quality, and provide solutions to nuclear
waste problems. SNH agrees that environmental objectives should
not be limited to reducing carbon emissions, but recommends that
such environmental objectives should also include protecting the
quality of the natural environment.
Scotland's natural heritage is of renowned quality,
with many of its landscapes, habitats and species subject to international
and national recognition. 11 per cent of Scotland's land area
is designated as Site of Special Scientific Interest; of that
a proportion is designated under the European Habitats and Species
Directives, and further areas including marine areas are being
added; 13 per cent of the land area is designated as National
Scenic Area; and action to establish Scotland's first two National
Parks is currently in train. Outwith these areas, Scotland's landscapes,
habitats and wildlife are also of high value and of economic importance
for leisure and tourism and the environmental services they provide.
Tourism in Scotland accounts for some eight per cent of all employment.
It is therefore important that the environmental objectives for
energy policy include conserving the quality of the natural heritage.
It is worth noting that this has not always been the case in the
past: the large-scale hydro developments of the post-war years
significantly altered many of the landscapes of Highland Scotland.
Assessment of the cost of energy schemes should take into account
the environmental costs of such impacts. In choosing between energy
sources, the price of services to the consumers should not be
driven down if in doing so significant environmental costs are
The Review proposes that any future energy related
policy needs to be assessed to determine whether it is consistent
with the fundamental goal of moving towards a low carbon energy
system. Decisions on future options for energy policy as they
affect Scotland should also take full account of the consequences
for the quality of Scotland's natural heritage, alongside the
impacts of climate change resulting from greenhouse gas emissions.
Further, paragraph 3.96 identifies the need
to assess the impacts of any proposed energy related policy instrument
or package on environmental objectives other than those contributing
to climate change. This conclusion is not, however, included as
a recommendation to take forward. We recommend that any policies,
plans and programmes relating to energy, as they affect Scotland,
should be based on a full strategic environmental assessment of
their environmental consequences. Such an assessment should take
account of the lifetime environmental impacts associated with
each form of energy, including the impacts of fossil fuel extraction,
and the storage and disposal of waste, as well as any ongoing
pollution impacts and impacts on landscapes and wildlife.
Analysis of scenario based projections of supply
and demand in the long (2050) and short (2020) term are detailed.
The PIU estimates from scenario based evidence that it seems possible
to deliver the reduction in carbon emissions of 60 per cent by
2050. This, however, requires continued and substantial progress
in energy efficiency, the construction of a large, low carbon
electricity system, major progress towards a low carbon road transport
sector and managed growth in air travel. It further concludes
that significant carbon emission reductions and reductions in
the demand for energy services are only achieved in scenarios
where policy and social changes give substantial weight to environmental
goals. In energy supply, there is most scope for change in electricity
generation, in particular through the expansion of the role of
renewable energy and CHP.
We are supportive of the recommendation that
energy efficiency should be at the centre of low carbon energy
strategies, and that there is need for new targets in energy efficiency
in all sectors. The Review has considered the potential of energy
efficiency schemes, energy efficiency in transport, housing improvements
and CHP generation. It is disappointing however, that the Review
does not consider in depth how policy could influence the overall
levels of demand for energy services. The potential for encouraging
long term changes in lifestyle, which could have effects on demand
for energy services, especially transport, is not looked at in
There is a real risk that in the short-term,
the potential for development of renewables could obscure the
need for energy reduction measures. Developing renewable energy
could be used as a means of soaking up new energy demand without
reducing existing fossil fuel consumption. For example, we are
concerned that the current target of 5 per cent increase in renewables
is set against a projected rise of 4.5 per cent in electricity
demand over the period to 2010. Current DTI projections of energy
use are for continued growth of around 0.5 per cent per annum.
SNH therefore considers that the top priority
in energy policy should be to reverse this trend of continued
growth, by encouraging the reduction of energy needs, though efficiency
measures, better use of waste heat, managing travel demands, and
changing attitudes and behaviours and considerations of energy
use and environmental impacts in other policy spheres.
The Review emphasises the very significant role,
which new renewable energy opportunities could play in a low carbon
energy system. SNH agrees with this position and recognises the
contribution renewables can make towards an overall programme
to address climate change. Broadly, SNH will endorse its policy
position on renewable energy (see above) in response to the Review.
The Review makes a specific recommendation that
the target for electricity produced from renewable sources should
be increased to 20 per cent by 2020. In the light of the recent
Garrad Hassan report, commissioned by the Scottish Executive,
on the potential of renewable energy sources in Scotland, SNH
considers that a further increase in new renewable electricity
in Scotland of this order is likely to be achievable. However
it will require careful guidance over the type and location of
renewables projects if it is to be achieved with a minimum impact
on the natural heritage.
At Annex 1 we set out our detailed comments
on the potential of each renewable technology in turn, in relation
to their likely impacts on the natural heritage.
The Review recognises that the range of renewable
energy technologies represent the most important priority among
low carbon supply options. It also notes that "Institutional"
barriers need to be overcome if the UK is to meet its current
target of 10 per cent electricity met by renewables by 2010. There
is a perception of energy projects having difficulty gaining planning
permission. We draw attention to the fact that this statement
is much less true of Scotland where the success rate for renewable
energy applications if very significantly higher than in England
SNH sees it as a 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.
The recently revised National Planning Policy guidelines on Renewables
development (NPPG 6 revised 2000) is favourably disposed to wind
farm developments. It creates a facilitatory planning environment
in which planning authorities are encouraged to develop locational
guidance or to specify more detailed criteria within Structure
Plans for renewables development in their area. The guidance steers
development away from sites designated as of national importance
but gives only general guidance in relation to areas of local
value. There is litter guidance given in relation to the potential
cumulative impact of development. These are issues we consider
should be addressed to ensure a strategic approach. SNH would
be concerned if planning guidance for renewables moved further
in the direction of a presumption in favour of development. Any
proposals to streamline the planning process for major infrastructure
proposals should not be at the expense of considering all the
issues fully, including consideration of natural heritage impacts,
or of the involvement of consultees and the public. Similar considerations
should be applied to generation licences under the Electricity
The selection of appropriate locations for development
to date has been very much led by competition to attract subsidies
that were awarded preferentially to generators able to offer the
lowest unit costs. This drove developers to sites, which were
economically attractive but often very undesirable from a natural
heritage standpoint. The announcement of the Renewables Obligation
(Scotland) provisions has improved the situation, in that developers
are now searching right across Scotland for sites which are economic
within the constraints of a +3p per unit premium; but it is still
market-led rather than led by where the environmental impacts
can be minimised. We suggest that this is an area in which an
objective of liberalising markets and developing competition has
in the past taken precedence over an objective of minimising environmental
impacts with unfortunate results for the natural heritage. We
are in favour of a stronger national steer, including targets,
on the most appropriate areas for energy projects, as we believe
this is an essential element of a strategic approach within which
local decisions can be made about specific projects.
The Garrad Hassan report, and an earlier report
commissioned by the Scottish Executive from Scottish Power and
Scottish and Southern Energy, has made clear that the development
of renewables will rapidly become constrained in Scotland by limitations
in grid capacity. Even the targets for 2010 can only be met if
renewables projects are located such as to match the current spare
grid capacity, largely within the Scottish central belt. If wind
and marine resources are to be developed on a more widespread
scale, this will require enhancement of the grid system, particularly
to transfer electricity from northerly and westerly parts of Scotland,
where wind and wave regimes are generally highest, to central
Scotland where the supply is needed. Enhancement of the grid is
likely itself to have significant landscape and other natural
heritage impacts. Any strategic consideration of the impacts and
location of renewables development in Scotland should also include
consideration of the grid strengthening required and the environmental
impacts associated with this.
The establishment of a Sustainable Energy Policy
Unit bringing together responsibilities for climate change, energy
policy and transport is logical, given the proposal that sustainable
development should be a guiding principle. It will be important
that there will be liaison and participation with other environmental
interests and with the devolved administrations. SNH would support
corresponding arrangements being made in Scotland. Such an arrangement
should play an important role in ensuring that the development
of renewable energy proceeds in a way, which takes adequate account
of economic, social and environmental interests.
Conventional objectives of security
of energy supply and economic competitively should be integrated
with environmental and social objectives.
Environmental objectives should not
be limited to reducing carbon emissions but should include maintaining
the quality of Scotland's natural heritage.
Energy options as they affect Scotland
should be informed by a strategic environmental assessment of
lifetime impacts of each option.
Top priority should be attached to
securing energy demand reduction, through energy efficiency, housing
improvements, CHP schemes and changing personal behaviour.
SNH supports the development of renewable
resources in Scotland, but that support is conditional upon a
strategic approach to guide it towards the locations and technologies,
which can be accommodated without diminishing the quality of Scotland's
landscapes and habitats. This is of particular importance in the
short-term for onshore wind.
Offshore wind, wave and tidal resources
may have the potential to offer energy with relatively limited
environmental impacts. Further work to investigate the issues
and develop strategic and locational guidance is required.
SNH considers that an expansion in
renewables of the order projected by 2020 is achievable in Scotland,
but to avoid undue impact on the natural heritage, careful guidance
is needed on the types and location of renewables development,
which is appropriate.
SNH would be concerned if planning
guidance for renewables in Scotland moved further in the direction
of a presumption in favour of development.
The environmental impacts associated
with developing the grid to accommodate renewables should be taken
SNH would support arrangements being
made within the Scottish administration to join up energy interests
with environmental and social interests, to secure an integrated
view over energy options in Scotland and in particular for renewable