Select Committee on Environmental Audit Appendices to the Minutes of Evidence


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 Impact Assessments.


  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.


  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.


  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 incurred.

  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 detail.

  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 and Wales.

  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 Act.

  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 into account.

    —  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 energy.

April 2002

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