APRS Resources

Ofgem consultation on Energy Transmission

This is our response to the Ofgem consultation on energy transmission infrastructure, 16 July 2025

RIIO-3 Draft Determinations for the Electricity Transmission, Gas Distribution and Gas Transmission sectors 

With over half (£4.7bn) of the proposed investment into GB’s high-voltage electricity network allocated to Scotland (via SSEN and Scottish Power), and an overall ambition to deliver 3,500km of new circuits, we are concerned about the impact this will have on Scotland’s communities, landscapes, and biodiversity. We appreciate the urgent need to modernise and build grid capacity in the transition to renewable energy, however this shift is happening without adequate, holistic strategic planning that considers the long-term impacts on landscapes, communities, and the environment. It is crucial that we address the twin crises of biodiversity loss and climate change, ensuring that one is not expedited at the expense of the other.

Energy infrastructure planning, including this proposed grid expansion, should be strategic and landscape-sensitive, ensuring that developments are proportionate, suitably located to minimise impact, and deliver lasting benefits to communities and the environment. Wherever possible, in areas of high landscape value, transmission infrastructure should be located underground, and we would like to see sufficient funding ringfenced for undergrounding in national parks, national scenic areas (NSAs) and  local landscape areas, to protect the value of these areas. This could be achieved through the continuation and expansion of VISTA (Visual Impact of Scottish Transmission Asset), fully funded by Ofgem into the RIIO-3 price control period.

We would also like to see renewed commitments from SSEN and Scottish Power to appropriately and fully engage with communities in affected areas to ensure their needs, and the needs of the local environment, are protected. We ask for Community Benefit Funds (e.g. SSEN’s CBF) for all areas of transmission infrastructure at an adequate level to ensure that communities in Scotland hosting any new transmission infrastructure will benefit from the transition to renewable energy. Network operators and developers must balance development with landscape protection, biodiversity recovery, community benefit, and long-term resilience to ensure a just and sustainable transition for Scotland.

APRS, July 2025

Back
to top