Memorandum 75
Supplementary evidence from RWE Innogy
(Npower Renewables Limited in the UK) following evidence session
on 30 January
This memorandum is in response to additional
evidence requested by the Innovation, Universities and Skills
Committee in the course of the Committee's inquiry into renewable
electricity generation technologies.
Mr Kevin McCullough, Chief Operating Officer
of RWE Innogy (operating as Npower Renewables Limited in the UK),
provided oral evidence to the Committee on Wednesday 30 January
2008. During the evidence session, Kevin McCullough was questioned
by the Committee on the subject of the positive social and environmental
impacts of renewable electricity schemes on the local area. In
his response, Kevin McCullough gave examples of the kind of benefits
such schemes can bring to the local community, including job creation,
education, and community benefits packages. The Committee expressed
an interest in receiving further written evidence of examples
of environmental and social benefits, such that it can be included
in the Committee's final report.
This memorandum outlines evidence available
to RWE Innogy/Npower Renewables Limited of the positive social
and environmental impacts of renewable energy schemes, with a
particular focus on job creation, community benefits packages,
local environmental benefits and changing public attitudes.
In addition, we have taken this opportunity
to expand on two further important issues that we feel are relevant
to the Committee's inquiry. With relation to the draft Planning
Bill, which was discussed at some length during the oral evidence
session, we include further detail on our proposal to ensure that
renewable projects below the 50MW threshold are treated in a consistent
manner to those under the remit of the Infrastructure Planning
Commission. We also wish to bring to the Committee's attention
the issue of potential interference to civil and military radar
from operating wind turbines, and highlight the extent to which
this issue is currently impacting on the deployment of wind energy.
SECTION 1: POSITIVE
SOCIAL AND
ENVIRONMENTAL IMPACTS
OF RENEWABLE
ENERGY SCHEMES
Job creation
The construction and operation of wind farms
can help benefit the local economy through job opportunities and
contracts for local businesses. One of the first significant benefits
of a new renewable electricity project is the effect on employment
and economic activity in the local area during construction, where
local businesses are often best-placed to secure contracts. There
are employment opportunities in the development, construction,
operation and maintenance of UK wind farms.
At npower renewables[258]
sites we expect around a quarter[259]
of capital costs to go to the regional[260]
economy in which the development is located, which is evidenced
by the recent construction of three of our largest wind farms.
— Contracts for the construction of
npower renewables project Ffynnon Oer Wind Farm in Neath Port
Talbot, Wales, awarded 22.5% of expenditure to UK based companies.
Many of these UK companies are civil and electrical engineering
businesses. This is despite no UK companies tendering for the
supply of the wind turbines, which comprise the largest component
of expenditure for the wind farm construction phase.
— A similar split was seen during the
construction of npower renewables' Causeymire Wind Farm near Wick
in Scotland, where 22% of the capital cost was spent in the UK.
Over 35 local businesses benefited from supplying services during
the construction period. These services included providing accommodation,
IT support, civil engineering, fuel and concrete.
— Farr Wind Farm, located in Inverness-shire,
Scotland, saw significant contracts awarded to Scottish companies
for the electrical, civil and grid construction work with further
contracts for smaller works and supplies also going to local companies.
These contracts make up approximately 25% of the total capital
costs of the project.
Across this portfolio of some 170MWs, we estimate
that approximately £30million of project expenditure was
spent in the regional or UK economy.
While wind farms and other renewable facilities
are typically not labour intensive once constructed, local jobs
can be created to fulfil operations and maintenance requirements.
For example, 10 full-time positions in operations and maintenance
at the North Hoyle Offshore Wind Farm project have been filled
by people living locally to the project.
Further afield, the growth in renewable technologies
is helping to build a new manufacturing sector in the UK, particularly
in the marine renewables sector.
Community Benefits Packages
npower renewables works closely with local communities
to optimise the benefits associated with the development and operation
of new sites. Community benefits are additional, voluntarily benefits
over and above any economic benefits realised by the wind farm.
These benefits may be environmental, educational, social and/or
economic and are usually targeted at those communities living
closest to wind farm developments.
npower renewables typically works with local
people to ensure that the community benefits package is tailored
to specifically meet the needs of the local community. To date
community benefits packages have included energy efficiency measures,
schools education programmes, local event sponsorships, equipment
for schools, youth groups and sports clubs, repair works to village
halls and other community building and funds which can be accessed
by local community and voluntary groups.
Typically, a community benefit package comprises
an annual (indexed-linked) payment throughout the operational
life of the wind farm, some 20 years. In some cases a one off
donation is made when the wind farm is commissioned.
For example, the Bears Down Wind Farm community
fund is focused predominantly on 19 local schools which were each
presented with computer equipment worth a total of £60,000.
Ongoing annual donations of £1,000 per school (index-linked)
continue to be made to the seven secondary schools to help with
the running costs of the computers. In addition, an annual community
fund of £3,000 (index-linked) has been established to benefit
the wider community over the life of the wind farm. To date, these
funds have supported a number of groups including local sports
clubs, senior citizens days out, local theatrical events, a local
environmental enhancement scheme and an environmental education
project with local schools. The whole community fund package over
the life of the wind farm will be worth in the region of £300,000.
Local Environmental Benefits
At a national, indeed global, level, all of
the renewable electricity projects that npower renewables develops
have clear environmental benefits, helping to reduce carbon dioxide
intensity in electricity production and combat global warming.
There are however, often specific opportunities to exert a positive
impact on the environment at a local level.
For example, we are currently developing a wave
scheme to be located near Siadar, on the Isle of Lewis. The scheme
would involve building a breakwater, which could provide some
protection for a slipway/harbour facility. It is anticipated that
this facility would help to develop small boat, commercial and
leisure craft facilities and thereby boost local infrastructure.
Changing Public Attitudes
As a developer, we believe we have a role to
play in educating the public about the important role of renewable
electricity in our future energy mix. Further, we have surveyed
the changing attitudes and opinions of residents and visitors
in areas close to our renewable electricity projects as a means
of monitoring the impact of our activities on the general public.
Numerous independent public opinion studies
consistently show that the majority of people support the development
of renewable energy projects in the UK. Those that are not supportive
are mostly neutral in opinion with only a very small minority
actually objecting to renewable energy schemes. Survey results
have also demonstrated that prior to development becoming a reality,
people perceive greater impacts than those which they actually
report experiencing once the project is up and running.
As a company, we have commissioned independent
surveys to monitor public attitudes and opinions to our renewable
project developments. We submit as evidence to the Committee,
the summary results of two surveys, conducted prior to and post
the construction of North Hoyle, the UK's first major offshore
wind farm, in 2003 and 2004 respectively (appendices 2 and 3,
note that the first survey was commissioned under the name National
Wind Power before the company was re-branded as npower renewables).
Headline results show that since construction was completed, support
for the project has increased, with 73% of residents saying they
are in support compared with 62% before the wind farm was constructed.
Just 5% of residents say they oppose the project. The high level
of public support demonstrated in the results is consistent with
our experience of previous surveys undertaken at our operating
onshore wind farm sites, and elsewhere across the UK. The British
Wind Energy Association (www.bwea.com) report the findings of
the "Wind Tracker", which is a recurring survey of public
attitudes to wind energy in the UK, conducted by leading independent
research company GfK NOP. The latest results show 76% of people
in Great Britain agreed that wind farms are necessary so that
we can produce renewable energy to help us meet current and future
energy needs in the UK.
SECTION 2: THE
DRAFT PLANNING
BILL IN
RELATION TO
SUB 50MW RENEWABLE
SCHEMES
The draft Planning Bill was discussed at some
length during the oral evidence session. Here we summarise our
view on the Bill and include further detail on our proposal to
ensure that renewable projects below the 50MW threshold are treated
in a consistent manner to those under the remit of the new Infrastructure
Planning Commission (IPC).
We welcome the Planning Bill and see it as an
important step forward in providing the necessary consenting regime
for future energy infrastructure. The provisions of the Infrastructure
Planning Commission (IPC) for determining applications over 50MW
in size should result in a smoother, more predictable consenting
regime. An important part of this will be the wholly new National
Policy Statements which, by providing the criteria against which
proposals will be judged, will provide the core basis on which
the decisions of the IPC will rest.
Within the renewables industry there is, however,
concern as to the treatment of the considerable number of renewables
proposals that fall below the 50MW threshold. We estimate that
circa 30% of all MWs submitted for planning determination are
in this category. It is anticipated that a significant proportion
of future renewable proposals, in particular onshore wind proposals,
will also fall below the 50MW threshold. This does not, of course,
mean that the total contribution from onshore wind energy is small—on
the contrary, it is a large and vital component of achieving both
the 2010 and 2020 renewables targets. It is also important to
note that smaller independent and community developers will tend
to have more projects in this category and therefore it is particularly
important that this sector is given equal treatment to those in
which large companies operate. As in all growth industries, the
role of SMEs ensures a strong focus on innovation.
This issue was discussed in some detail during
the Committee's oral evidence session on 30 January 2008 and we
would like to take this opportunity to further clarify our preferred
approach to ensuring consistent of treatment of sub 50MW projects
under the Town and Country Planning Act (TCPA) alongside those
that will be submitted to the IPC.
It is vital that the National Policy Statement
(NPS) on Renewables—which has been agreed through an extensive
consultation process and will be the key policy document for all
renewables proposals coming before the IPC—should apply
to those renewables proposals which fall below the 50MW threshold.
This can be achieved, provided Government adopts
the correct wording in the Planning Bill currently before Parliament.
What is required is that:
(a) The NPS on Renewables already proposed
for adoption under provisions in the Planning Bill should be also
made a statutory component of the Local Development Frameworks
which planning authorities adopt for planning control purposes.
To simply "have regard" to national policy statements
in formulating local development plan policies would not, in our
view, go far enough. There needs to be a clear statutory requirement
that any development plan must broadly conform with any relevant
national policy statement, particularly in relation to renewable
energy projects, and that any substantial divergence should have
to be justified to the Secretary of State.
(b) Policies in the renewables NPS should
be accorded the same weight in the determination of renewable
energy applications made under the Town and Country Planning Act
as they would have been given if the proposal had been determined
by the IPC.
The these two steps would mean that where there
is clear guidance on generic issues in the NPS which are relevant
to the application in question, then that guidance would be applied
consistently across all projects, regardless of size. Further,
we feel that developers should be able to have recourse to an
effective formal complaint procedure if it is evident that generic
issues, on which there is clear guidance in a national policy
statement, are being re-examined at local level. It is very important
that arguments surrounding generic issues, on which national policy
has been established, are not allowed to consume the resources
of local authorities during the decision process or public inquiries.
SECTION 3: THE
ISSUE OF
AVIATION RADAR
IN RELATION
TO RENEWABLE
SCHEMES
In the course of its inquiry, the Committee
has rightly focused attention on the barriers to the deployment
of existing renewable technologies. Existing technologies, in
particular onshore and offshore wind, are viable and cost effective
and hence have the capability to meet a significant proportion
of the Government's current targets.
In addition to previous evidence submissions,
we wish to bring to the attention of the Committee the concerns
around potential interference to civil and military radar from
operating wind turbines. This issue, which has recently attracted
considerable media attention,[261]
currently places a significant constraint on scheme development
(both in the area of pre-planning and within the planning process)
and thereby presents a significant barrier to the deployment of
wind energy and hence to the achievement of UK renewables targets.
So far as we are aware, this is an issue which the committee has
not as yet addressed in the course of its inquiry.
Wind turbines can appear on the screens of both
civil and military radar operators as "clutter" (ie
unwanted returns), and there is potential for wind farms to obscure
other (wanted) radar returns or to produce the appearance of aircraft
returns where no aircraft is actually present. It is of course
the case that radar pictures also contain other unwanted clutter,
for example from rain and other weather events, moving road and
rail traffic, flocks of birds etc, and indeed the operators of
radar systems are trained to identify and cope with such clutter.
Objections stemming from a wind farm being in
"line of sight" of radar (including MoD, NATS and CAA)
severely constrain wind farm development and are a major barrier
to both onshore and offshore wind deployment. In particular, a
substantial number of wind farm proposals at an advanced stage
of development are currently threatened by MoD objections, which
appear to arise from the application of a line of sight assessment.
A wind farm existing in the line of sight of aviation radar need
not necessarily lead to difficulties—a further step to include
risk based assessment will allow the significance of the impact
to be properly assessed. In this regard, a greater understanding
between parties needs to be developed in order to better define
where wind farms can exist without compromising the needs of the
aviation community. This is likely to require a high level of
cooperation on both sides.
If current constraints can be lifted, even partially,
then large areas suitable for wind farm development will be opened
up. However if this issue is not addressed urgently there is significant
risk of hiatus in wind development and build.
Indeed, in a recent speech, Gordon Brown highlighted
this issue and has asked that Des Browne, John Hutton and Ruth
Kelly "step up their efforts in cooperation with industry
and the regulators to identify and test technical solutions to
the potential difficulties that wind farms pose to air traffic
and defence radar".
Technical advances have been identified that
would assist in mitigating these problems, some of which may be
adopted over time through the natural upgrading of existing radar
installations. These technical solutions now need to be funded
and tested.
Whilst cooperation between interested stakeholders
on these matters is generally good, we are concerned that the
issue needs to move beyond discussion and into working compromises
and solutions. We would particularly commend the work of BERR
in ensuring this is the case and that technologically driven solutions
are identified where they appear possible. However, the funding
gap remains, and a timescale of several years is likely before
the full impact of these solutions becomes a practical reality.
It is therefore essential that all stakeholders—including
Government departments—work together to ensure that barriers
to renewables deployment are removed. We would encourage the Committee
to include aviation radar in its remit and to highlight the urgent
need for solutions to be funded, tested and implemented.
March 2008
258 Npower Renewables Limited is a wholly owned subsidiary
of RWE Innogy. Back
259
The word "quarter" is based on the figure of 23%.
The word "quarter" has been used as it is more clearly
understood than the % figure, and it gives us the ability to use
a more rounded figure. The "quarter" figure is an average
based on three of the most recent wind farms built by npower renewables.
We have based the figure on our own experience as this is felt
to be most defendable and relevant to our own activities. Details
from these wind farms have been supplied by the relevant project
manager and are summarised in the text above. Back
260
The term "regional" is a hard area to quantify. For
clarity the term "regional" refers to the geographical
areas into which npower renewables has divided up the UK (ie Scotland,
Wales, East of England, North of England and South & West
Midlands of England). Back
261
Article in The Times 4 February 2008, "Two targets, one
dilemma: to defend the Earth or the skies?" Back
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