This is our response to the Government’s Draft Energy Strategy and Just Transition Plan which we submitted on 9 May 2023.
APRS is a Scottish charity that has been speaking for nearly 100 years on behalf of Scotland’s countryside, its landscapes and nature and for the people who live, work and enjoy rural Scotland. Our reputation is for sound, practical, professional advice and effective campaigning that takes into account Scotland’s wider interests and the long-term future of our Nation. We have a long record of helping Government reach good policy outcomes.
We welcome the ambition in the Plan, but also recognise that in needing to take a truly transformative approach and driven by both the climate-imperative and the economic opportunities renewables present, it is very tempting to focus on solutions without proper consideration of the unintended, and indeed adverse associated consequences. We believe that the inevitable impacts should be mitigated properly, and that, where choices have to be made, the broader implications are wholly considered.
In summary we feel the draft Energy Strategy and Just Transition Plan could be improved in the following areas.
- A better recognition of landscape and the potential impacts on it and possible mitigations within the plan.
- A stronger emphasis on energy reduction and support for a Circular Economy as a key policy response
- A clearer commitment to strategic, planned approach to energy infrastructure.
- A recognition that renewable expansion is not without negative consequences and the need for efforts to minimise impacts including those on communities and the environment and landscape, both on an individual development scale and collectively.
- A more just and robust mechanism for community contributions and a much stronger support for community generation.
- A commitment to securing net-positive benefits for biodiversity and recreation with respect to new developments and upgrades.
- Additionally, we would encourage you to consider some wider informal engagement perhaps through a series of workshops to establish good dialogue and to foster greater understanding and partnership on some of these issues.
The full response:
This is a bold and ambitious plan that will form a key initiative in Scotland’s combined response to reducing Climate Change. As the Plan recognises, changes in climate will be, and indeed are already beginning to be, highly impactful and far reaching to all of us in Scotland and to the Global Community. While there are opportunities and some positives the majority of change will be adverse, uncertain, and at a high societal cost. Not just inconvenient, costly or even-life-threatening, Climate Change has the potential to pose an existential threat to humanity if our response is inadequate.
There is a profound urgency needed to achieve rapid decarbonisation of the economy: while we may be aiming for Net Zero by 2045 in Scotland, our direct and indirect use of carbon needs to reduce very rapidly, as current levels of carbon-use are at such a rate that we will find it impossible to limit climate change to 1.5C as identified by the Paris Agreement, even if we secure the 2045 target.
It is also important to recognise that while the Plan may bring about a transformation in energy use, the technologies it may herald are not likely to be permanent in the long-term and they may likely be replaced in time with others. By way of illustration, 19th century society embracing coal and steel to drive an industrial economy appeared entirely logical at the time, but few now would not agree that with current knowledge and hindsight, the outcomes of the Industrial Revolution could have been so much better, avoiding many of the physical scars of bings, industrial pollution and associated dereliction along with social ills of gross poverty and impacts on health and well-being. Equally, the twentieth century development of the network of hydro-electric generation was transformative, bringing to bear the best of engineering prowess, yet for all its transparent continued worth as a renewable asset, the profound effect on catchments and the extensive damming of rivers has had an extensive impact both on rural communities – and on our natural biodiversity, including very visibly on Scotland on salmon populations. Better planning and impact mitigation employed 90-70 years ago would have even further enhanced its legacy. Commercial afforestation is a later example of how a hugely important and generally successful industry could have been much better delivered if greater care had been taken with planting in decades-past.
The case for demand reduction and efficiency measures
Energy is absolutely fundamental to modern society, and even with a more circular and decarbonised economy accompanied by greater energy efficiency, it seems as a society we will have an increasing demand for greater electricity generation. Our natural resources lend themselves to Scotland becoming a renewables exporter, but we need to recognise better than previous generations, the importance of not consuming or destroying our natural assets for relatively short-term benefit, and to take full account of long-term consequences.
The Plan aims to reduce energy demand across Scotland, mentioning changes in travel, greater home energy efficiency and also more efficient use of energy by industry. APRS endorses this and believes that there is a need for even greater emphasis on energy reduction in the Plan. Some of Scotland’s key industries are very energy intensive. In addition, the provision made for energy saving is clearly inadequate: the £1.8 billion identified for energy efficiency equates to less than £700 per dwelling.
Steps to achieve energy reduction will not be without controversy, and will not be easy. APRS has been supporting the Deposit Return Scheme through our Have you the Bottle Campaign for a number of years. It is a good example of how a process shift in industry can save significant amounts of energy. Yet the scheme has been delayed several times by the Scottish Government following Parliamentary approval as a result of pressure from industry. The result of this delay has not only contributed to continued littering, we estimate it has resulted in approximately an additional half a million tonnes of carbon dioxide being released to the atmosphere.
We would suggest that a focus on energy reduction needs to be driven by Government but that individual action and engagement is essential for its success.
Embodied Energy and the Circular Economy
The Plan also gives poor consideration of the embodied energy in the products we consume, and how so many of these are imported, and thus the true costs of production and often disposal are externalised. The development of the Circular Economy is certainly a key to this, although its emphasis tends to be domestic, and it is important that Government continues to support rapid progress in this field.
The strongest emphasis should be made on supporting the Circular Economy, with the minimising of the use of materials and recycling of materials for renewable infrastructure. In particular, there should be strong emphasis on reducing the embodied energy of new infrastructure.
The importance of Landscape in the consideration of Energy Infrastructure
One of the principal concerns of APRS is landscape and it is easy to see this as simply “scenery”, but that is to miss what we mean by landscape or its true importance, which encompasses the whole human interaction and appreciation of the land. Historically damaged and despoiled landscapes contribute to poverty, blight communities, lead to chronic ill-health and well-being, and cause biodiversity loss – which globally is considered as an existential threat as climate change in the view of the majority of the scientific community. In contrast, healthy ones offer prosperity and well-being. It may seem seductive to see renewables as a relatively clean technology, and thus as being nothing other than benign. Indeed, renewables are a good option, as an environmentally response to addressing the consequences of our lifestyle, but it is also impossible to ignore that renewables, as a highly dispersed form of energy generation have a very significant impact on our landscapes, through not only as a result of extensive developments but also through transmission, sub-stations, and the structure and creation of new industries.
Nearly twenty years ago, work funded by partners that included: The Scottish Government, SEPA, Scottish Enterprise, and Forestry Scotland and that was published by Scottish Natural Heritage, demonstrated how fundamental environmental assets were to underpin economic growth and concluded that output from activities which depend on the natural environment was estimated to be the valued at £17.2 billion a year, then around a 11% of total Scottish output. This represented 242,000 jobs, or 14% of all full-time jobs in Scotland. Since then, the value will have increased considerably not just due to inflation but because of the value being placed on natural resources including the landscape. This study and subsequent work on Natural Capital emphasises the importance of employing considerable sensitivity and care in driving forward the undoubtedly important programme of renewable development.
It is APRS’s view that to mitigate the impacts of the expansion of renewables, the current Plan needs to better recognise landscape and demonstrate more fully both an awareness of the impacts and how to mitigate these. To achieve this, it is vital that the Plan reflects and references the policies recently set out in the National Planning Framework 4. Although there is now a published map of Wild Land in Scotland produced by NatureScot, the lack of an indicative strategy for terrestrial wind development has helped neither the industry who are left with an uncertain picture, nor planners and those wishing to safeguard the finest and most sensitive aspects Scotland’s landscape, so we call for a strategic approach that includes indicative mapping of sensitive areas both on land and at sea. This needs to embrace not only the sites identified for generation but also the consequential impacts of new transmission lines etc. In particular National Scenic Areas and National Parks require special protection as recognised in NPF4. In particular, we would emphasise that marine areas further off-shore may be out of sight, but they still have significant environmental impacts, including landscape implications.
Where impacts are unavoidable then planning conditions must be actively used to ensure that there is compensation for the broader impacts of development. For example, where recreational opportunities are being lost, then investment could be secured for alternative recreational infrastructure to compensate for this. To this end there should be a commitment that new renewable investment should have a net-positive impact. There are many opportunities for this even with improvement of existing infrastructure: for example, hydro-schemes due for up-grade should be re-evaluated for options for the improvement of fish migration, creation of new spawning areas, and for the creation of floating wildlife refuges on variable level dammed storage. Before new hydro is considered, existing schemes should be assessed to ensure existing technology is appropriate and efficient.
Where there are potential adverse consequences, proper consideration of opportunities to ameliorate these should be considered, for example under-grounding of transmission in key locations. It is vital that the costs of this mitigation is internalised, i.e. that it is seen as part of the cost of the development and borne by the developer. There should also be thought given to the capacity of advisory and regulatory agencies to respond to what will be a step change in development activity. How can this be funded? There must be an adequate mechanism to ensure proposed developments adequately contribute to the costs of assessment to ensure this is done both well and in a timely way.
In the case of solar, we strongly advocate that development rights should not be given in perpetuity, and that a restoration bond should be used to ensure the ultimate reinstatement of land.
There is a need for the creation of land use strategies to consider all the different pressures and demands being placed on land (nature recovery, reforestation for nature, or production forestry, biofuels or agricultural food production or solar/renewables or housing etc). Land is a finite resource and this urgently needs to be considered.
In terms of protection of soils, NPF4 already identifies the importance of protecting Scotland’s soils, but it is worth restating the importance of maintaining the asset of more productive agricultural land when proposals such as p.v. farms are being considered. This is a recommendation within the Strategic Environmental Assessment Appendix B.
The importance of benefit for Scotland’s Communities
There is now a well-established system of community contributions that are generated by terrestrial wind farms in recognition of the impacts these large developments have on the community and a sharing of the economic benefits locally. However, such arrangements are currently inequitable and voluntary. They leave some communities with an embarrassment of funding, while neighbouring communities receive nothing, even though they may be impacted by transmission lines, construction traffic, and other infrastructure. A good example is given by the new Green Free-port on the Cromarty Firth where renewable development is having a major impact on local communities but they see little or no direct economic benefit. A fairer system of sharing the benefits and mitigating the impacts needs to be found: one that reflects the disproportionately high impact these developments have on fragile, rural communities; one that better reflects the true size of the revenue streams generated; and that shares the resources across the wider community.
More generally, it is a concern that the major investment envisaged by the Plan will be driven by large multinational companies, and that aside from community contributions and general taxation, the economic benefits will not accrue to Scotland, especially under the current political settlement. It seems to us the case for a nationally owned energy company should be examined as a way of securing greater national benefit.
The Potential for locally produced energy and community and co-operative ownership.
The Plan rightly recognises that for such a significant change in energy supply, there will need to be truly significant investment in new infrastructure. However, we believe much more can be achieved by local and domestic energy generation to increase capacity, in particular photo-voltaic cells (p.v.). At present increasing this capability is very tightly regulated, and there is an assumption that generation should principally be matched to immediate on-site demand. Encouragement of generating electricity locally using pv on houses, barns and small ground arrays has many advantages; the investment cost is widely-shared; the economic benefits are widely dispersed and based in the community, and there is the potential for community groups to benefit as well as individuals. Since transmission is one of the key losses for energy generation, generating close to need is efficient, while the ownership and management of on-site power develops a much stronger culture of energy-use awareness by users. Scotland has the powers through building regulation to set minimum standards for all new-builds and substantial renovations to include PV (and energy storage), with exceptions for historic buildings or where efficient generation is not viable (for example due to aspect). In these cases, developments should be required to secure equivalent generation capacity elsewhere in other renewable projects. This vision of greater dispersed community generation could usefully be added to the visioning in the Plan.
In addition, there sems scope to encourage the development of co-operative and co-ownership of renewable development, allowing a broader community investment into these key national assets.
Protection of Public Access Rights
Scotland’s access rights have been hard won and they represent progressive measures that many would argue are the mark of a country focused on well-being and fairness, to say nothing of the economic value outdoor recreation generates. The Plan envisages development that cumulatively will involve a significant land take: it is vital that in this that public access rights are retained.