Memorandum submitted by Scottish Natural
Heritage
1. Scottish Natural Heritage (SNH) is a
non-departmental public body funded by Scottish Government and
responsible through Ministers to the Scottish Parliament. Our
purposes are to promote the care and improvement, responsible
enjoyment, greater understanding and appreciation, and sustainable
use of the natural heritage, now and for future generations. The
natural heritage embraces landscape, habitats and wildlife, and
the capacity that these have to contribute to people's well-being.
SNH is an adviser to Government and to planning authorities on
natural heritage matters, including on the impacts of electricity
infrastructure, and a statutory consultee on environmental impact
assessments and strategic environmental assessments.
2. Electricity networks have a very significant
impact on Scotland's natural heritage, particularly through the
visual and landscape effects of the many overhead pylon lines
constructed to serve Scotland's communities, and to harvest "power
from the glens" in the mid-20th century programme of hydropower
development. In localised areas in or adjacent to protected sites,
bird impacts can be a concern, but these have normally been resolved
by careful routing and mitigation (e.g. bird deflectors).
3. The requirements to enhance the grid
in Scotland have increased because of the scope for wind power
and will increase again in future to enable the potential to be
realised for wave and tidal power, for which much of the UK resource
is in north and west Scotland, and offshore wind.
Q1. What should the Government's vision be
for Britain's electricity networks, if it is to meet the EU 2020
renewables target, and longer-term security of energy supply and
climate change goals?
4. By 2050, if the Climate Change (Scotland)
Bill is passed, Scotland like the rest of the UK will have a target
of reducing greenhouse gas emissions by 80%. Given the substantial
residual emissions from land use change which it will not be possible
to eliminate, and the likely continued dependence on fossil fuels
for some modes of transport, this would require electricity generation
to be virtually carbon-free by 2050. This will require a change
in approach so as to ensure that the electricity grid is capable
of collecting all forms of renewable energy both on and offshore,
and facilitates the development of small-scale and distributed
generation. Given the long-term nature of energy infrastructure,
it is important that this aim is reflected in all decisions on
new infrastructure and substantial refurbishments from now on.
5. To do so, grid networks should:
— enable electricity to be collected from
those areas rich in renewable energy resources and where there
is environmental capacity (e.g. parts of upland Scotland for onshore
wind, tidal streams in north Scotland, wave power in north and
west Scotland, offshore wind).
— minimise any problems arising from the
intermittency of renewables, and the need for backup conventional
generation.
— enable distributed and small-scale generation
to become a reality, allowing small scale renewable generators
and distributed plant including CHP to be developed locally, so
as to meet local demand, reduce the need for strategic interconnection,
and helping to foster a new public awareness of the relationship
between energy use and the requirement for energy infrastructure.
— deploy best environmental practice, placing
a much higher priority on undergrounding of electricity networks
or the use of undersea cables so as to reduce visual and landscape
impacts, albeit with recognition of potential impacts on habitats
and the need to secure an appropriate cost balance.
Q2. How do we ensure the regulatory framework
is flexible enough to cope with uncertainty over the future generation
mix?
6. At present the regulatory framework is
demand-led, that is the electricity network is developed by transmission
companies in response to demand expressed by proposals for new
generation. This process is inadequate in the face of current
needs for a strategic change to equip the UK in meeting climate
change targets. While demand-led regulation may operate at a lower
level, there is a need for Government to develop a high-level
strategy for the development of the electricity network, as a
key infrastructure requirement. That strategy should be developed
taking account of:
— associated potential environmental impacts—e.g.
by undertaking a strategic environmental assessment. The impacts
considered should include the visual, landscape and biodiversity
impacts associated with overhead power lines and buried cables,
as well as the climatic benefits of enabling the UK's climate
change targets to be met;
— the available renewables resource in different
parts of the UK and surrounding waters, and their ability to accommodate
such development within their environmental capacity;
— the uncertain timescales over the development
of technologies such as wave power or carbon capture and storage.
The strategy might identify a number of options, deployment of
which would depend on such technological progress. It should take
account of the risks and uncertainties for generating technologies
throughout their life-cycle; and
— the need for network infrastructure to
be resilient to the impacts of changing climate and associated
weather events, weather patterns and coastal and river flood risk.
In this connection we are aware of the recent
report by the Electricity Networks Strategy Group "Our Electricity
Network: a Vision for 2020" which is a welcome forward look
at requirements to 2020. However we note that it is purely a technical
appraisal in terms of expected transmission requirements; it does
not include any environmental considerations.
Q3. What are the technical, commercial and
regulatory barriers that need to be overcome to ensure sufficient
network capacity is in place to connect a large increase in onshore
renewables, particularly wind power, as well as new nuclear build
in the future? For example issues may include the use of locational
pricing, or the availability of skills.
7. In Scotland, there has been widespread
development of onshore wind power and there are many new proposals
in the planning pipeline. While there are some grid capacity limitations
in south Scotland, it seems likely that these can be addressed
through grid reinforcement or new grid sections without major
contention. For north Scotland and the northern islands, however,
there is a need for major new network capacity between the demand
centres of central Scotland and distant areas of prime wind resource
including Morayshire, East Highland, Caithness and Shetland.
8. We point to four ways in which regulation
might be improved.
(i) Setting environmental standards
9. SNH was an objector at the Public Local
Inquiry for the Beauly-Denny strategic grid enhancement. While
we supported the overall need for a grid enhancement in principle,
and stressed that support at inquiry, we were not satisfied that
the transmission companies had undertaken a sufficiently thorough
exploration of alternative options, including the option of undergrounding,
in two sensitive sections—one of which was where the proposed
line would cross the Cairngorms National Park. That exploration
only took place through the public inquiry as a result of the
interventions by SNH, the relevant planning authorities and many
other parties.
10. Some see this as an example of a "regulatory
barrier" which has delayed an important proposal by a period
of years. Our view is that it is indicative of a lack of Government
encouragement as to the need to pursue best environmental options
in developing electricity infrastructure. Currently there is a
"vicious circle" in which Ofgem interprets its requirement
to regulate to protect the interest of consumers as meaning that
network developments should be identified at lowest cost; while
the grid companies argue that if they design developments other
than at lowest cost, they will not be approved by Ofgem. Ofgem
accepts that a higher cost option may be necessary if it is deemed
to be a requirement by the planning system. This approach sets
up the planning system as a "regulatory barrier" and
in our view is likely to lead to continued contention over major
grid proposals in the future.
11. We strongly recommend that Government
articulates some clear guidelines on the expected environmental
standards of electricity network development and associated energy
infrastructure. These guidelines should include acceptance that
higher cost options including undergrounding of high voltage cables
or the use of undersea cables are required in some locations in
order to avoid potential adverse impacts on landscapes and local
communities. Underground and undersea cables are by no means a
panacea—they have many associated environmental impacts
of their own—but should play an important role in enabling
a UK electricity network to develop without an overall increase
in wirescape impacts.
(ii) Use of underground and undersea cables
12. The use of high-voltage underground
cables for strategic grid lines has to date been limited in the
UK, but there is considerable experience elsewhere in Europe.
The use of solid dielectric cables has now generally replaced
the use of oil-filled cable technology, even at the highest voltages,
thus avoiding the potential oil pollution problems associated
with the latter. There is a need to promote greater confidence
in the use of underground cable technology, by ensuring free flow
of information on any problems in installation and use.
(iii) Consents process for underground high-voltage
cables
13. There is an anomaly in the consents
system, in which overhead power lines of voltage 20kV or more
require ministerial consent under Section 37 of the Electricity
Act, while underground power lines, at whatever voltage, do not.
Nor do they require planning consent, as they are deemed permitted
development (in Scotland, under the General Permitted Development
Order). We currently have the situation in Scotland in which a
strategic high voltage electricity link is being proposed between
Beauly and the Western Isles, deploying an underground DC cable
across nearly 50 miles of the Scottish Highlands, without a need
for planning or Electricity Act consent. Installation of an underground
cable is no minor work—it involves disruption of ground
on a scale similar to that required for a pipeline installation,
and there are cable joints and cable heating effects to be considered.
14. Consent is however required, from SNH, where
such a cable affects any site of special scientific interest.
SNH may therefore in the position of exercising a consent over
small parts of a major linear engineering project, in principle
without the need to consider the project and its benefits within
the context of the development plan. We suggest that this is an
anomaly which should be put right—for example through inclusion
of underground cables above a certain threshold capacity or voltage
within the scope of Section 37 of the Electricity Act, and possibly
by qualifying the scope of permitted development status within
planning legislation. This would enable Scottish Ministers or
the planning authority to take a view of the project as a whole,
including any impact it may have on SSSIs, seeking advice as required
from SNH. While this might be seen as an additional regulatory
requirement, rather than overcoming a regulatory barrier, in the
long term it will be in the interest of transmission companies
that major transmission routes carry the consent of the local
authority. There is no need for such a new regulatory requirement
to impinge on the present ability for low voltage local cables
to be undergrounded as a form of permitted development.
(iv) Rules for grid connection
15. In some parts of Scotland renewable
generation proposals have been delayed because of a lack of grid
connection capacity. We welcome the flexibility applied by Ofgem
in some "Renewable Energy Zones" whereby new renewable
generation can be developed on the basis that at times it may
be constrained off. This seems an appropriate approach, particularly
for outlying or island areas, where there is a reasonable expectation
that grid connection capacity will be enhanced in the future.
Q4. What are the issues the Government and
regulator must address to establish a cost-effective transmission
regime?
16. We identify three issues:
— Regulators should have as a key objective
the need to secure carbon reductions compatible with the targets
in the UK Climate Change Act and Climate Change (Scotland) Bill.
Therefore, decisions should be taken which are consistent with
the overall emission factor for UK electricity supply reducing
over time, in accord with the needs of the climate change programme,
and with a goal for 2050 of having a virtually carbon-free electricity
system.
— Offshore renewables development offers a
clear opportunity for Government to adopt a strategic approach
to the provision of grid connections, with a view to minimising
the number of offshore cables laid, the number of grid landfalls
and the need for associated grid infrastructure at the coast,
and the overall disruption to the seabed. Such an approach should
also help to reduce duplicative costs. Where a grid connection
is developed as a component of a specific generation development
(rather than part of the nationally-operated grid), the regulatory
system needs the ability to oblige an operator to make spare capacity
available, under reasonable network access rules, to other generators.
— Through Ofgem, Government has established
a high level of electricity network reliability through the application
of national grid standards including the requirement that the
grid system has a high level of redundancy built in, such that
failure of any one component will not disrupt electricity supply.
SNH is not able to comment on the need for or desirability of
maintaining these grid standards across all parts of the UK. However
we suggest that Government needs to keep under review whether
these standards remain appropriate and cost-effective, in circumstances
where there is a wider range of generation sources than hitherto,
and, in due course, where the level of distributed and embedded
generation may be sufficient to provide electricity to meet those
electricity needs deemed essential.
Q5. What are the benefits and risks associated
with greater interconnection with other countries, and the proposed
"supergrid"?
17. Interconnection with other countries
would enable the UK to minimise the level of little-used conventional
power generation capacity which may otherwise have to be installed
simply to cover for intermittency in renewable generation.
Q6. What challenges will higher levels of
embedded and distributed generation create for Britain's electricity
networks?
18. Embedded and distributed generation
may in early years be less reliable than current major plant.
However once developed in number they will provide a level of
local supply which should reduce the risks associated with strategic
grid failure and reduce the need for conventional plant to cover
for the intermittency of large-scale renewable generators. The
challenge for electricity networks is to provide the flexibility
needed to accommodate any intermittency in local production, and
to enable connection to the grid at a cost which is not a disincentive
to the development of embedded and distributed generation.
Q7. What are the estimated costs of upgrading
our electricity networks, and how will these be met?
19. No comment.
Q8. How can the regulatory framework ensure
adequate network investment in light of the current credit crunch
and recession?
20. As explained above (Q3) we believe there
should be a strong element of Government vision in the development
of a strategic grid network. Government could place an obligation
on grid companies to develop plans and to secure approval for
the development of networks which match up to that Government
vision. That would not of itself ensure network investment, but
it would ensure that when that network investment funding becomes
available, it can be translated with immediate effect into implementation
of agreed plans, rather than triggering the start of a lengthy
planning process. There would be a need to approve early expenditure
on the development of such plans.
Q9. How can the regulatory framework encourage
network operators to innovate, and what is the potential of smart
grid technologies?
21. One of the main and commonest arguments
made against renewable technologies is that they are intermittent,
and therefore require back-up by fossil fuel power stations which
may remain unused for large periods of time. Smart grid technology
should be seen as an important tool in accommodating intermittency,
for example by activating local or distributed generators, or
by limiting non-crucial demand, at times when there is a shortfall
in supply, and by directing electricity to storage systems (heat
or electricity) at times of surplus. The development of storage
systems may require new incentives.
22. In the future, when it may be expected there
will be very substantial dependence on renewable generation, it
seems likely that the concept of "electricity demand"
will have to become more clearly structured into, for example
"essential demand", "desirable demand" and
"optional demand" so as to facilitate active demand
management by grid operators. Structuring demand in this way would
enable peak load periods to be spread, using smart grid technology
in combination with differing tariffs for different types of demand.
Reduced peak loads would translate into a reduced overall requirement
for energy infrastructure.
Q10. Is there sufficient investment in R&D
and innovation for transmission and distribution technologies?
23. No comment.
Q11. What can the UK learn from the experience
of other countries' management of their electricity networks?
24. Our impression is that there is considerable
experience of installation and operation of high voltage underground
cables elsewhere in the world. It would be helpful to ensure that
such experience is collated in an open, transparent way so that
there is a widely shared understanding of best practice and the
construction and operational costs of such installations.
March 2009
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