Mareike Moeller-Holtkamp Scottish Natural Heritage

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Mareike Moeller-Holtkamp Scottish Natural Heritage Leachkin Road Inverness IV3 8NW 28 January 2013 Dear Mareike Revised Strategic Locational Guidance (SLG) for onshore windfarms – Consultation – Scottish Natural Heritage (SNH) Thank you for the opportunity to comment on what is an important issue for the onshore wind industry in Scotland. Scottish Renewables is the representative body for the renewable energy industry in Scotland, with over 320 member organisations. As you know, this industry is playing a crucial role in Scotland’s efforts to tackle climate change, reduce impacts on consumer energy bills and increase Scotland’s energy security, and must continue to do so in order to meet our renewable energy targets and carbon emissions reduction target of 42% by 2020. The enclosed response has been formulated by Scottish Renewables following internal discussion within our membership. This response addresses the consultation questions in turn in an annex to this letter. Key points from our response are as follows:     

The SLG should be more focused on official designations and avoid expanding further into other areas which are best judged on a case-by-case basis. SNH should avoid mapping sensitivities which are out with their remit, namely the carbon content of soils. It should be made clear that the document is for SNH staff to use internally and that it should not be used as the basis for evidence for other decision makers. The SLG should make it clear that decisions on local sensitivities be made on a case-by-case basis. Therefore, the most sensitive areas as highlighted by the SLG should be official designations. We understand and support the need for the guidance to be updated to include new SPAs and the expansion of the cairngorms National Park boundary.

If you have any further work arising from this consultation or would like clarification on any of the detail in this correspondence please do not hesitate to contact Scottish Renewables. Yours sincerely

Joss Blamire Senior Policy Manager, Onshore Renewables

Scottish Renewables Response to Scottish Natural Heritage’s ‘Revised Strategic Locational Guidance for onshore windfarms’

1) Are there any other natural heritage designations / protected areas which you think we should add to the SLG mapping? Scottish Renewables has significant concerns about the Revised Strategic Locational Guidance. There is a significant shift within the revised strategic guidance in respect of the landmass covered by the Highest Sensitivity (Zone 3) designation. It is noted that of this additional 29% of landmass intended to be covered by this High Sensitivity designation, a limited amount includes the extension to the Cairngorm National Park and the six additional Special Protection Areas. Such inclusions are national and international designations respectively and as such merit inclusion. It is further noted however, that the significant extension to this High Sensitivity designation is due to the inclusion of the new GIS layers which identify sensitive peatlands and carbon rich soils. Many of these areas have been mapped as Zone 3 due to their blanket, or raised bog status being classed as a primary or secondary habitat mosaic, however most of these areas do not carry national, or international designations in their own right. Scottish Renewables is very concerned about the new additions to the SLG which concern peatlands. Scottish Renewables has worked with the Scottish Government, SEPA and SNH, along with academics and other stakeholders to develop a robust carbon calculator tool for assessing the impact of wind farm developments on peat. The results of this tool are now a material consideration for Ministers and form a key part of the application process. Developers are aware that peatland may be a constraint but work to ensure that, where development does occur on such areas, the effects are well mitigated through careful siting and designing. Scottish Renewables has also worked with other stakeholders, including SNH, to ensure that there is guidance available for constructing sites on peat and for dealing with waste peat on a site. We would like to understand more about why, at this stage, SNH have decided that peatlands should now be part of the SLG. The rationale for inclusion in the SLG is that carbon rich soils are particularly important for mitigating climate change as they store carbon. We agree with this statement, but feel that there is already sufficient recognition and protection of these soils through the carbon calculator and the EIA process and enough information and guidance available to ensure appropriate considerations and mitigations are made. Therefore, we do not see the merit in SNH including this as an area with the highest possible grading for natural heritage sensitivity. We would suggest that the carbon aspect of the mapping of peatlands is removed from the SLG. It is possible that SNH could map individual habitats which are sensitive, but this would be a far more focused map of particular areas and habitats, rather than the inclusion of peatlands as a whole.

Similarly, we have some concerns about the inclusion of wild land in this mapping process, as it is also undesignated. However, we are working closely with SNH during their review of wild land in Scotland and would like its impact on the SLG to be part of on-going discussions.

2) Do you think that other sensitivities which relate to enjoyment of the natural heritage such as Long Distance Routes, National Tourist Routes and Scotland’s Great Trails should be added to the SLG? If so, in which zone? 3) Key transport routes (such as major roads, railways and ferries) are sometimes viewed as sensitive to wind farm development, depending on the location. Is this sensitivity throughout their length, or does it relate to the natural heritage characteristics and qualities that a route is passing through? Should these be identified in the SLG mapping? If so, in which zone? 4) The Munros and Corbetts are a well-known and highly valued recreation resource. The views from popular summits are generally viewed as sensitive to wind farm development. Do you think these summits should be identified in the SLG? If so, in which zone? Scottish Renewables would like to make the same general points in response to questions two, three and four. For these factors, assessment of the impact of a wind farm on the sensitivity to natural heritage should be considered on a case-by-case basis. It is unrealistic to assume that SNH can map, at a national level, the impact a single site could potentially have on any of these factors. Furthermore, the inclusion of sensitivities without any official designations sets a dangerous president for a huge host of interests to be considered at this national, strategic level. For example, the sensitivity through key transport links will vary greatly depending on the location of a wind farm site and the characteristics of the local landscape. The same could be said of a Munro’s sensitivity to development. Scottish Renewables sees no reason in adding more factors to the SLG, which could and should be judged on a case-by-case basis. The inclusion of such factors has the potential to make local SNH officers and other decision makers far more wary of development before a developer has even had a chance to show how they plan to design a site as part of the local landscape.

5) In some areas the cumulative effect of wind farms on the natural heritage is such that there is limited scope for further development. Would it be helpful to identify these on the SLG maps, and if so, how? Scottish Renewables would not encourage the inclusion of cumulative impacts to be mapped as part of the SLG. Information and guidance on consideration of this sensitivity is already well documented by SNH through the ‘Siting and Designing

Wind Farms in the Landscape (2009) and ‘Assessing the cumulative impact of onshore wind energy developments’ (2012) documents. Echoing our earlier points, we feel developers should be given the scope to mitigate and innovate, allowing them to submit applications where they feel they can be acceptable to the local area. SNH should then use judgement on a case-by-case basis as to whether the developer has achieved this. Designating areas for or against development on a national basis sets a president for all future developments in the area, despite the possibility that local characteristics are subject to change and that developers can find appropriate mitigations for certain areas which may be deemed acceptable following full scrutiny via the planning process. Wind farm developers choose sites based on a huge number of factors. SNH should primarily focus on highlighting areas with national and international designations to ensure that developers gain a clear understanding of these constraints. By including further, more complex and less clear potential constraints, SNH will create a great deal of uncertainty for developers, potentially effecting investment in onshore wind developments.

6) Some areas in Scotland are characterised by different patterns of windfarm development. In Aberdeenshire, for example, developments of 2-3 turbines are common; whilst in the Central Belt and Southern Uplands, larger wind farms are more common. Would it be helpful to identify these patterns in the SLG to try and encourage a consolidation of these? SNH’s suite of landscape character assessments already provide the steer on the scale of development that can be accommodated within each landscape character. We do not see it as appropriate to class certain areas of Scotland as being appropriate for certain types of development. Landscape can change dramatically in a local area and developers should be left to make applications which are most suited to the local landscape, taking into account of other developments in the vicinity. 7) In some areas there is a need to maintain gaps between wind farms, or groups of wind farms to prevent visual coalescence. Would it be helpful to include a map which shows where we think these gaps should be? Developers already consider cumulative impacts at an early stage and this forms a significant part of the EIA for development. The aim to retain gaps between wind farm developments to prevent coalescence relates to cumulative visual impact and is not a strategic element that can be effectively mapped in a broader spatial sense. This aspect may be better indicated in planning authorities’ spatial frameworks, due to its localised nature and impact and subsequently addressed by the individual merits of a proposal through the development management process. 8) Many Planning Authorities have completed Landscape Capacity Studies for wind farms. Do you think the areas identified should be included in the SLG?

Scottish Renewables would say that at this stage, local Landscape Capacity Studies (LCS) should not be included in the SLG. Many of the LCS’s are not yet complete in Scotland and, where they have been, they often ignore the guidance set out in SPP which relates to how they should be produced. In addition, the SLG should retain focus on nationally sensitive designations. Developers will already take into account any locally produced guidance. 9) Do you have any other suggestions for ways in which the SLG mapping and the guidance could be improved? Scottish Renewables encourages SNH to keep the SLG as simple as possible, highlighting the important, designated areas of natural heritage sensitivity to ensure developers and SNH officers and other decision makers are clear about and the impact of siting a windfarm in such an area. The SLG should not include:  sensitivities which are out with SNH’s remit (such as carbon sensitivity of Scottish peatlands);  areas which do not have any official designations (some areas of wild land and carbon rich soils). These areas should certainly not be classed as having the highest sensitivity.  sensitivities which are best judged at a local level (Munros, transport links etc). The inclusion of a range of potential sensitivities creates the possibility that developments will be significantly hampered and sites which may be perfectly reasonable and appropriate for development become highlighted as an area which is highly sensitive. The SLG should focus on designated sensitivities to make the guidance, and the impact the guidance may have on planning decisions, less ambiguous.