South Ayrshire Council has produced some very useful comments in their further objection to Clauchrie WF – please see below. Many of their arguments will apply to other applications.
The Applicant sets out the positive benefits of the Proposal on ‘contribution to renewable energy generation and targets’ for the Examination to consider. No doubt anticipating the changes introduced in LDP2, they state that “the total energy output from the site would be approximately 320 GW hours per annum … the equivalent of around 84,000 UK households … contributing to targets for renewable energy” (EIAR 1.3.3 {para 11}.
They state the Proposal will “make a valuable and tangible contribution to climate change targets and achieving government renewable energy targets” (Planning Statement 3.1). They calculate the Proposal will have Net Emissions of Carbon Dioxide of 291,08 tCO2eq and Carbon Payback against grid-mix emissions of 4.9 years. They also state the Proposal would have a 216,000 tCO2eq per annum saving over coal-fired electricity, a 106,000 tCO2eq per annum saving over fossil fuel mix electricity and 60,000 tCO2eq per annum over grid-mix electricity.
Given these positive benefits the Proposal can be judged, in the light of the LDP2 changes, in a more appropriate balancing of potential positive benefits of a wind farm against possible negative effects. However, before doing so it is necessary to review and test the Applicant’s claim on the positive benefits.
In respect to ‘contribution to renewable energy achieving net zero targets’, the Applicant’s claims of emissions saving against coal-fired electricity generation are somewhat spurious. They obviously fail to recognise that their parent company closed the last coal-fired generation in Scotland in 2016. Without current coal-fired generation in Scotland there can be no emission gain and no contribution to meeting emission targets against coal.
Similarly for the Applicant’s claims in respect of fossil fuel emission savings. At the present time Scotland’s electricity generation is provided by wind energy, hydroelectric power and a nuclear plant (Torness) with only one fossil fuel power station in Scotland, at Peterhead. It is understood that the gas fired power station at Peterhead only operates when wind energy is not being produced, i.e. when the wind is not blowing. Consequently, the Proposal will not make any contribution to saving fossil fuel emissions in Scotland.
Given the mix of electricity generation in Scotland at the present time the Applicant’s claimed grid-mix emissions savings must also be in grave doubt.
The Energy Statistics for Scotland Q1 2022 (June 2022) state that “in 2020 each kilowatt hour of electricity generated in Scotland added an estimated 33.6 grams of carbon dioxide into the atmosphere”. The grid emissions are below the Scottish Government ambition for 2020.
This indicates that the basis for the Applicant’s claims on grid-mix emissions savings are unsound. Given the exceedingly low level of grid-mix emissions in Scotland and that the only fossil fuel generation station only operates when wind energy is not being produced, it is evident that the Proposal cannot make the contribution to grid-mix emissions claimed by the Applicant. Accordingly, the claimed potential positive contribution to achieving net zero targets through the generation of renewable energy’ in Scotland will not materialise. Unfortunately, the Applicant’s figures are not substantiated.
The energy circumstances and issues in relation to the extent to which a windfarm might contribute to ‘renewable energy and Scottish net-zero targets’ have been outlined (since the Energy and Planning Policy Hearing Session in June 2021) by the Scottish Government in October 2021. The Government undertook a detailed assessment of issues for wind farm proposals in the Onshore Wind Policy Statement Refresh Consultative Draft 2022 (OWPS-Refresh). This updated re-assessment has also been undertaken since the Applicant prepared their EIAR and submitted their application, on which they base the ‘contribution’ merits of the Proposal. The OWPS-Refresh sets out the current position (as at October 2021) on the deployment of wind energy, the future position and details various “barriers to deployment” together with the economic opportunities. The OWPS-Refresh states the position of wind energy in Scotland is that there is 8.4GW of existing built capacity, with 5.07GW consented either under or awaiting construction and 4.69 GW in the planning pipeline (OWPS-Refresh 1.2.3 and 2.1.3 respectively).
Interestingly, this compares with Scottish average electricity demand of merely 2.6GW indicating that there is already a considerable excess of wind farm capacity in Scotland. After taking account of Scottish nuclear generation (Torness circa 1.0GW), the excess over demand is 6.8 GW for operational capacity and 11.87 GW over for the combined operational and consented capacity. The OWPS-Refresh also recognises that the repowering of ageing wind farms and extensions to newer wind farms could produce substantial amounts of increased wind farm capacity, without needing to issue consents on virgin sites such as that selected for this Proposal.
As noted, the OWPS-Refresh identifies a number of ‘barriers to deployment’ for wind energy. These include limitations due to aviation (as discussed in the Session), grid and regulatory limitations, network charging, the need for biodiversity, landscape and visual impacts. Arguably the most important of these barriers to affect the LDP2 criterion on contribution to reaching net-zero targets and renewable output is the challenge of ‘grid, networks and regulatory’ (OWPS-Refresh 3.4).
The Scottish Government has recognised that the recent rapid growth of wind farms in Scotland has created substantial challenges for energy infrastructure in the inadequacy of the transmission networks both within Scotland and between Scotland and England.
By way of example the transmission lines between Scotland and England typically operate at a capacity of 4.5 GW. This means that the excess Scottish wind farm capacity (6.8 GW) often exceeds the export transmission capacity from Scotland.
Consequently, wind farms in Scotland are often turned off, or curtailed, because the electricity output cannot be used.

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