I am truly blown over by the Scottish Government’s Onshore wind policy statement 2022, which contains astonishing levels of illogicality and dubious assumptions. The obvious failings of the document are legion – certainly on too great a scale to keep this analysis within reasonable bounds if I were to dwell on them all – so instead I will dip in and out, highlighting some of the most obvious nonsense, and leaving the interested reader to explore the original document if desired.

Ministerial Foreword

This is written (or at least signed off) by Michael Matheson, the Cabinet Secretary for Net Zero, Energy & Transport, and it’s fair to say it sets the tone for the nonsense that follows. It commences on a contentious note:

The world is facing a climate emergency with the impacts of climate change already being felt across the globe. From floods in Pakistan to drought across Europe and last winter’s serious storms, the damage that unmitigated climate change can cause is already clear to see.

Given that the IPCC Sixth Assessment Report Working Group 1 nowhere (not even in its Summary for Policymakers) uses the phrase “climate emergency” (nor “climate crisis”, for that matter) it seems rather strange that the opening paragraph of a government policy statement should set the policy framework by reference to terminology beloved (and, in this context, arguably invented) by the mainstream media rather than by the international experts who pontificate on this topic at great length on a regular basis.

The second paragraph is arguably even stranger, given the wealth of fossil fuels available to the Scottish government if only they decided to permit their exploitation and use (as the SNP part of the Scottish government coalition used to urge only a few short years ago when claiming that these fossil fuel riches provided the basis for their desired Scottish independence). Here’s the second paragraph:

Russia’s illegal invasion of Ukraine and the resulting extraordinary rise in the price of fossil fuels, in particular gas, demonstrates that continuing to rely on commodities that are subject to global price shocks is no longer an option.

Admittedly that was written in 2022, but one assumes that such matters as important as national energy policy (and the statements that apply to them) are kept under regular review by politicians and their advisers. Presumably, then, they have noticed that a gas price which peaked at over £7.00 per therm in late August 2022 is sitting as I write this at just over one-sixth of that peak, at 121.2p per therm. Of course that fall in price might not be permanent, and it doesn’t of itself render void the claim that it might be unwise, say, to put all one’s eggs in the basket of products that might be subject to price shocks, but it does cast doubt on the argument that continuing to rely (at all) on such products “is no longer an option”.

Having recognised the tendentious nature of those opening two paragraphs, the next sentence (which is of critical importance, underpinning as it does the whole policy statement) offers up a shocking non-sequitur:

That is why we must accelerate our transition towards a net zero society.

I find that form of words to be a curiously inelegant and unhelpful way to express the reasoning (such as it is) behind the Scottish government’s energy policy. We aren’t told what “that” is, and are left to draw the inference that the reason(s) is/are as set out in the two preceding paragraphs, namely the dubious claim that the world is facing a climate emergency and the equally dubious claim that because fossil fuel prices spiked for a relatively brief period on the back of a sudden and irrational warlike move by a Russian politician who will not be in post for ever, energy policy that relies on fossil fuels is therefore “no longer an option”.

Given that the UK as a whole is responsible for around 1% of the world’s ongoing greenhouse gas emissions, and given that Scotland’s population is around one-twelfth of the UK’s population, one has to wonder on what basis the elimination of fossil fuel use by Scots responsible for around one twelve-hundredth part of the global total is expected to play any part in resolving the global “climate emergency”. Given the cost and inconvenience associated with an accelerating transition to net zero, one might have hoped to see a detailed analysis of the nature of the Scottish climate emergency (rather than a vague reference to floods in Pakistan, drought in Europe and serious winter storms) and an explanation as to how Scottish net zero policies can stop these things from happening, espcially in the face of rising fossil fuel use elsewhere in the world – you know, a bit of real global context. And one might expect an explanation as to why it is deemed unwise to use one’s own fossil fuel resources, given an issue with potential “global price shocks”.

Sadly, as we will see, no such analysis is forthcoming. On the contrary, next we are told that:

...we must go further and faster to protect future generations from the spectre of irreversible climate damage.

Once again, the crucial piece of reasoning and explanation is missing. Even assuming that Scots people (or the human population and fauna and flora of the entire planet) are facing “irreversible climate damage”, we aren’t told how Scottish net zero will stave this off. Of course, the reason why we aren’t told this is because whatever the Scots do, it won’t make any difference to anything.

Nor is the significance of Scotland’s 2030 targets explained (hit that date and all will be well? Miss it and face climate armageddon?), but we are told that “…continued deployment of onshore wind will be key to ensuring our 2030 targets are met.” Hilariously (at least, it would be funny were the implications of such nonsense not so serious) we are told that “onshore wind is a cheap and reliable source of zero carbon electricity.” Reliable? 2021 wind drought, anyone? Cold, still, spells in the depth of darkest winter (when solar generation produces very little and the need for energy is acute) and the wind turbines stay stubbornly still?

Cheap? Well, this is the claim:

Despite being excluded from the previous two auction rounds, onshore wind achieved the second lowest overall strike price across all technologies at the Contract for Difference Allocation Round 4, at £42.47 per MWh, which is around 45% lower than it cleared during Allocation Round 1 in 2015.

True, so far as it goes, but it doesn’t go very far. There is not a single wind farm in the UK, let alone in Scotland, generating electricity at a price of £42.47 per Mwh, nor anything like it. Contracts for Difference aren’t really “contracts” in the traditional sense of the word, rather they are one-way options, and wind farm owners aren’t exercising the options at low strike prices when they have the option of taking the market price instead. Why does the foreword engage in this piece of legerdemain, instead of acknowledging the practical reality of wind energy pricing?

And so another set of dubious opinions are stated as fact:

Onshore wind has the ability to be deployed quickly, is good value for consumers and is widely supported by the public.

Maybe it is widely supported by the public who don’t understand its cost, unreliablity, unpredictability, and implications for the electricity grid and who don’t have to live anywhere near a wind farm, but that doesn’t mean it’s a good idea. And what about local democracy? People who live near the proposed sites of wind farms tend not to be so keen, and their objections tend to be ignored.

And then we get the final insult:

…it is also vital that this ambition [meeting net zero targets] is delivered in a way that is fully aligned with, and continues to enhance, our rich natural heritage and native flora and fauna, and supports our actions to address the nature crisis and the climate crisis.

Well, when are you going to start doing that? The apparent lack of awareness of the damage caused to Scotland’s ecology and environment by wind farms, and of the opposition to them by groups who value their local environment and care about flora and fauna, is staggering.

And that’s just the first page…

Ambitions and Aspirations

This section does at least have the merit of recognising that Scotland’s net zero plans will:

…see a substantial increase in demand for electricity…[which] will at least double within the next two decades. This will require a substantial increase in installed capacity across all renewable technologies.

Given that we are told that the net zero strategy will operate “across all sectors, including heat, transport and industrial processes” the idea that demand for electricity will only “at least double” in the next two decades strikes me as an heroic assumption, but then that is what we are told the National Grid’s Future Energy Scenarios says. Feel free to take a look. I’ve just spent ten minutes looking for that information there, and failing to find it.

However, I have found my way to the DUKES data provided by the UK government, including chapter one of its report on UK energy statistics for 2021. This tells us that:

With net imports up [in 2021], the UK increased its use of fossil fuels. The main fossil fuel sources in the UK are coal, gas and oil. In 2021, the share of primary energy consumption from fossil fuels increased to 78.3 per cent from the record low of 76.8 per cent in 2020, whilst that from low-carbon sources decreased to 19.4 per cent from the record high of 21.2 per cent last year due to reduced nuclear and renewables output…

In other words, renewables and nuclear combined (i.e. “low-carbon” sources of energy) provided only 19.4% of the UK’s energy needs in 2021 (remember the 2021 wind drought I mentioned above). If all sectors of the economy are to be “decarbonised” in accordance with net zero plans, then it looks to me as though electricity production will need to be five times higher than it currently is. Even allowing for the possibility of new technologies reducing demand for energy and even assuming that Scotland is further down this road than the rest of the UK, a claim that the demand for electricity in Scotland will only “at least double” over the next two decades looks ridiculously optimistic. Especially given that in Scotland the net zero zealotry of the government there has committed to an earlier net zero date than in the rest of the UK:

The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 (the Act) was passed by Scottish Parliament in September 2019. The Act commits Scotland to achieving net zero greenhouse gas emissions by 2045 at the latest, and also sets two interim targets to reduce emissions by 75% by 2030 and by 90% by 2040.

Leaving all that to one side, what then are the Scottish government’s ambitions and aspirations? They are to build on 8.7GW of installed capacity (NB, always remember that nameplate capacity and actual production are very different things) in Scotland as of June 2022, noting that up to 11.3GW of further capacity, spread over 217 potential projects will facilitate a “minimum installed capacity of 20 GW of onshore wind in Scotland by 2030“.

Lovers of the Scottish countryside and wild places, read it and weep.

Delivering on the Ambition for Onshore Wind in Scotland

The Scottish government tells us in this section that it:

is committed to achieving our climate change targets in a way that maximises the economic and social benefits of a just transition to a net-zero economy.

We are told that achieving this will require a collaborative approach, and to facilitate that, an Onshore Wind Strategic Leadership Group (SLG) is to be formed (oh good, another QUANGO – we don’t have enough of them, do we?). It will be tasked with identifying “solutions to key deployment challenges, establish opportunities to maximise benefits to Scotland, and foster a collaborative spirit across the sector, while aiding a just transition.”

I suppose I should be grateful to find recognition that there will be key deployment challenges, but don’t ask me to run this SLG – I can already see that its tasks are mutually inconsistent, especially given that it must also drive GVA (not defined, but I assume this stands for Gross Value Added). And I certainly wouldn’t want to be responsible for keeping order among the people who are to be involved:

…government representatives, onshore wind industry leaders, Scottish Renewables, relevant Scottish Government agencies and Supply Chain representatives and a body representing issues affecting local communities.

In fact, given the next paragraph, definitely count me out:

However, any future sector deal should reflect Scottish Government ambitions around supply chain, skills, increased deployment of onshore wind, community benefits and shared ownership, and positive biodiversity outcomes. It is crucial that the principles of a just transition are actively applied across the sector and that the benefits of the increased deployment of onshore wind are felt by all of Scotland’s citizens, especially in the communities that host developments.

That’s just not going to happen, is it?

For good measure, there are to be aspirations for the proportion of women to be employed in the onshore wind sector, at the same time. Fair enough, not a bad aspiration at all, but combined with everything else they are to be tasked with? Something will have to give.

Environmental Considerations: Achieving Balance and Maximising Benefits

This section makes a lot of the right noises, but really doesn’t engage with the single simple fact that building wind turbines in wild places is damaging to the environment. It even has the effrontery to talk about maximising the environmental benefits (sic) to Scotland. And, as is the case with stated UK government policy, it seeks to persuade us that mutually incompatible objectives will all be met:

The Scottish Government is committed to ensuring Scotland’s citizens have access to affordable, low carbon and renewable energy whilst tackling the climate and nature crises in tandem.

Reference is made to the Scottish government’s Land Use Strategy. Then we get another pie-in-the-sky statement of mutually inconsistent objectives:

As Scotland moves towards a net zero economy there will need to be significant land use change from current uses to forestry and peatland restoration. This needs to happen alongside ensuring space for other essential activities such as food production, renewable energy generation, including onshore wind, and the protection and enhancement of habitats and biodiversity.

Does this represent a faint stirring of awareness that onshore wind farms to date have often destroyed trees in extraordinary numbers (almost 14 million was the number quoted in 2020) and damaged peat, or are Scottish government ministers and officials in some strange state of denial as to the environmental damage caused by onshore wind farms to date?

Much is then made of the claim that degraded peat:

accounts for around 15% of Scotland’s total net emissions. Reversing degradation through peatland restoration is therefore central to mitigating and adapting to the linked climate and nature crises.

This claim is followed by the statement that peatland restoration is the way forward, despite the admission of yet another failure of the Scottish government to achieve its objectives:

Against our target to restore 250,000 hectares by 2030, we have delivered 57,500 hectares to date at an average annual rate of 5,700 hectares in recent years. This is below our annual goal of at least 20,000 hectares, and there are many reasons for this, not least that peatland restoration is a sector in its infancy and is building delivery capacity.

Don’t worry, seems to be the message, we’re getting there by “building delivery capacity”. Given the Scottish government’s track record over a whole area of policy issues, I doubt that any real progress will be made here. Ferries, anyone?

Bizarrely, given the repeated statements about the importance of peat, we then learn this:

We recognise, however, that the peatland impacts of onshore wind farms can be significant and we must balance the benefits from onshore wind deployment and the impacts on our carbon rich habitats. This includes being aware that there is potential for development in an area of deep peat to have a net negative carbon impact.

The Scottish government therefore commits to convene and expert working group (will that be yet another taxpayer-funded QUANGO?) and to

assess the operation of, and if necessary update or replace, the carbon calculator. The Scottish Government will ensure that adequate tools and guidance are available to inform the assessment of net carbon impacts of development proposals on peatlands and other rich carbon soils.

That would be the carbon calculator that has come under serious criticism of late and in respect of which a Scottish Government spokesperson said they “note the limitations” of the payback calculations, but said the calculator still provided “the best available means” to get figures in a “consistent and comparable format”.

This section (about the importance of peat) concludes with this solemn assurance:

By assessing the net carbon impacts of proposed developments on carbon-rich soils and peatlands we will ensure that planning and consenting regimes result in the right projects in the right places, with all applications considered on a case-by-case basis within the relevant planning regime.

Well, it would be a start, but it would also be a first. I trust that the Scottish people will hold them to that commitment.

Woodland is next up and we are told:

Creating new forests and woodlands is an important tool for reducing greenhouse gas emissions. For each hectare of forest and woodland created, it is estimated that, on average, seven tonnes of CO2 will be removed from the atmosphere each year. The Climate Change Plan includes a commitment to increase forest and woodland cover in Scotland from around 19% now, to 21% by 2032, and our 2020 update to the Climate Change Plan set out ambitious targets to incrementally increase woodland creation from 12,000 hectares per year in 2020/21, up to 18,000 hectares per year by 2024/2025….Protection of existing forestry, as well as expansion, is integral to our climate change targets. Woodland removal should be kept to a minimum and where woodland is felled it should be replanted. These aspects of Scottish Government policy, detailed through the Control of Woodland Removal Policy have formed part of the considerations for relevant onshore wind developments for more than a decade. This proves that the protection of forestry and the promotion of onshore wind already co-exist.

Proves? How is that consistent with the destruction by windfarm developers of almost 14 million trees to 2020, especially if this policy has been in place for more than a decade? Perhaps the reality is that policies, plans and aspirations count for nothing once the process of putting the wind turbines in place begins.

Aspiration and reality do seem to be in conflict, but not in the Looking-Glass world inhabited by the Scottish government:

Onshore wind will remain an essential part of our energy mix and climate change mitigation efforts, and the resolution of the balance between its deployment and biodiversity interests requires careful discussion and planning at a local level. As the rate of onshore wind deployment increases in the coming years, we see a great opportunity for wind energy developments to further contribute significantly to our biodiversity ambition. By proactively managing intact habitats and the species they support, restoring degraded areas and improving connectivity between nature-rich areas, onshore wind projects will contribute to our climate change targets and help address the biodiversity crisis.

Landscape and visual amenity are dealt with next. There is an admission that as wind turbines become ever larger and as there more and more of them to meet the government’s targets, “[t]his will change the landscape.” Whilst that is admitted, what is not admitted is that it will change the landscape for the worse. Yet such an acknowledgement is implicit in the recognition that wind energy is not supported in National Parks and National Scenic Areas. Ominously, however, “[o]utside of these areas, the criteria for assessing proposals have been updated, including stronger weight being afforded to the contribution of the development to the climate emergency…” In other words, the dice have just been loaded still further in favour of wind farm developers, because the reality seems to be that while the Scottish government recognises the serious adverse visual impact of wind turbines, it doesn’t really care:

Our Revised Draft NPF4 recognises that significant landscape and visual impacts are to be expected for some forms of renewable energy, and makes clear that where impacts are localised and/or appropriate design mitigation has been applied, they will generally be considered to be acceptable.

Finally in this section there is a recognition that noise, especially from the ever-larger turbines increasingly being used, can be a problem. The Scottish government notes that the current standard (ETSU-R-97) is being reconsidered by the UK government as possibly being no longer appropriate, given the increasing size of turbines, yet we are told:

Until such time as new guidance is produced, ETSU-R-97 should continue to be followed by applicants and used to assess and rate noise from wind energy developments.

And it might be argued that all the Scottish government can do is to wait and see if a new standard is put in place, though in reality there are two other alternatives. Given the centrality of onshore wind to its plans and the rapid growth in the size of turbines (with associated increased noise) the Scottish government could commission its own review rather than waiting for the UK government to do so. Or it could require new planning applications to be put on hold unless the proposed turbines are below a certain size, until the UK government review has been carried out. Neither option, it seems, has been considered. Locals (whether human or our furry and feathered friends) will just have to grin and bear it.

Benefits to Local Communities and Financial Mechanisms

This section is one where I have little to say, save that the experience of local communities might not fit with the Scottish government’s belief as to how these matters play out. For instance, this statement might ring hollow to many:

It remains vital that developers act as ‘good neighbours’, working in tandem with local communities, communicating over the course of a wind farm’s life and building good relationships. This should allow concerns to be addressed as they emerge, empower communities to engage positively with the development, and secure community enhancements.

Not living in Scotland, nor next to a wind farm, it isn’t really for me to comment further; rather it is for those affected (whether they feel the effect is positive or negative) to have their say.

I have already commented sceptically above on the claims made for Contracts for Difference (CfDs) in reducing costs. Despite the fact that not a single wind farm has been commissioned at the lowest CfD rates “achieved” recently, the Scottish government continues to proclaim that CfDs have driven costs down for consumers (at a time when costs have never been higher). Paradoxically, even so, they tell us this (which doesn’t sound like a recipe for positive progress):

Whilst the CfD is critical for delivering support to deployment at low cost to consumers, the pressure to reduce capital costs has had significant impacts on the domestic supply chain, with suppliers greatly reducing margins or losing contracts altogether. This is a result of the CfD scheme’s effectiveness in reducing developer bids and technology costs. The Scottish Government recognises that this pressure has had some negative effects on the domestic supply chain and investor confidence.

We are told that the Scottish government (in line with the UK government) “expects” “developers to make every effort to support the domestic supply chain…and to ask developers to provide UK content estimates for their projects as part of the Supply Chain Plan questionnaire.”

But expecting and asking isn’t the same as insisting, and in the absence of insisting via a contractual obligation, why would they developers do anything other than carry on as they have so far? Where did all the green jobs go indeed. Which leads us neatly in to the next section:

Onshore Wind and Benefits to Scotland

We are told that:

By capitalising on Scotland’s strengths in energy, natural capital, innovation and our skilled workforce and universities, we can set Scotland at the forefront of growing global markets.

Well, maybe, or maybe not. We are also told:

The recent Onshore Wind Prospectus suggests that approximately 17,000 jobs and the equivalent of £27.8bn in GVA could be achieved in Scotland if we are able to deploy an additional 12GW by 2030.

But suggesting is not the same as achieving, and even the Scottish government has to admit, somewhat sheepishly, that:

We recognise that, at present, the Scottish manufacturing supply chain for the wind industry is weak.

Yes indeed, and that is after decades of wind farm developments.

Almost incredibly, this section also suggests that wind farm developments will boost tourism. Ignoring the views of locals who know what is going on in their areas, we are instead rather pompously told:

The Scottish Government is aware that some communities in Scotland are concerned that the deployment of onshore wind can have a negative effect on tourism. Current evidence suggests that whilst there may be discrete impacts in some cases, this is not the general rule….We consider the effect that onshore wind farms can have on local and national tourism as a significant opportunity to cultivate a ‘people and place’ approach and provide economic opportunities in areas that may otherwise be overlooked.

Onshore Wind and Aviation Considerations

As noted in both the 2017 Onshore Wind Policy Statement, and the 2021 draft Onshore Wind Policy Statement (dOnWPS), wind turbines have the potential to impact aviation operations, including, but not limited to, impact on aviation radar.

Gosh, that sounds rather serious! Don’t be silly. It’s as nought compared to the climate crisis:

…the pace of deployment necessitated by the climate emergency means we must find a way to alleviate these impacts in an effective, efficient and timely manner. It is also important that solutions are cognisant of the cost of deploying renewable energy, particularly given the need to focus on both security of supply and low-cost generation, given the current international and economic situation.

Magic wand time?

Onshore Wind and Technical Considerations

The first technical consideration alluded to in the policy statement is that associated with wide loads. There will be more of these, and they will presumably be ever wider, as turbines grow in size. The problem is in fact considerable, and the Scottish government recognises it (though inevitably dismisses it, by assuming that the problem will be solved by the setting up of a series of working groups). Here is the problem:

As we increase the volume of onshore wind in Scotland…we will increase the volume of turbine components which must be conveyed to site. Abnormal Indivisible Loads are, by definition, a load being carried on a public road which exceeds a defined length, and hence could prove hazardous. Given the nature of wind turbine components, the movement of these parts will frequently trigger the Abnormal Indivisible Loads requirements.

Under the Road Traffic Act 1988, any abnormal load movement on public road in Scotland must be escorted by a specially trained police officer. This puts additional pressure on both Police Scotland and hauliers, as well as the wind energy sector’s ability to deploy at scale in Scotland.

In order to meet our legally-binding net-zero targets, it is estimated that 3400 turbines will be installed in Scotland between now and 2030, this is the equivalent of a new turbine being installed every day between 2025-2030. Given this, and the significant issues surrounding the transportation of components, this issue has been brought into fresh focus, as we consider it could have serious implications on the delivery of our renewable energy pipeline and subsequent threat to our 2030 net-zero targets.

There is another, associated, problem:

The Scottish Government is aware of the related, but separate issue of “oversail”, when turbine components “oversail” the boundary of a road and enter the airspace of private land at pinch points along the delivery route. The financial compensation paid to landowners is becoming increasingly substantial, and as we deliver the 3400 turbines between now and 2030 the financial implications of this issue has become more pressing.

But not to worry:

The Abnormal Loads Legislative Reform Sub-group will consider matters of land-ownership and oversail as part of their overall work package.

Just before leaving this section, it’s worth returning to the question of turbine noise (as the Scottish government does here in the context of a Ministry of Defence (MoD) seismological monitoring station at Eskdalemuir.

The array’s operation can be compromised by excessive seismic noise in the vicinity, which can be produced by wind turbines operating around the array.

And so the MoD has issued a direction which

…advised that any sites within 50km of the array would require consultation with MoD before determination. This 50km radius is often referred to as the ‘consultation zone’.

Within the consultation zone there is an existing hard no-build area at a radius of 10km from the array – no application for windfarms can be made closer than this due to the unacceptable impact they would have at this distance.

Needless to say, no such protection is offered to local residents living within anything like those distances from proposed wind farms.

Onshore Wind, Energy Systems and Regulation

So great are the issues, so many are the problems, that a rational person might sit down and question the wisdom of these plans.

Delivering our ambition of 20 GW of onshore wind by 2030 will create demands on our electricity infrastructure. New developments will need to connect quickly to Scotland’s distribution and transmission networks. Networks must be able to invest quickly and ahead of need in order to ensure swift and efficient connections for onshore wind developments.

The ‘connect and manage’ system has supported significant growth in clean, low-cost renewable capacity. However, the misalignment between rapidly increasing constraint costs and the long lead time for transmission investment is placing increased risk on consumers in an already challenging landscape.

National Grid Electricity System Operator, the GB Electricity System Operator, has identified the need for over £21bn of investment in GB transmission infrastructure to meet 2030 targets. Over half of this investment will involve Scottish Transmission Owners SSEN and SPEN.

Another obvious issue with the plan to build ever more windfarms in Scotland, is that they will be remote from many of the consumers of the electricity generated. In a sane world, this might be considered a relevant factor. But not in the world of net zero and the Scottish government:

In a net zero world, it is counterproductive in the extreme to care more about where generation is situated than what type of generation it is. A new approach is needed here, rather than small modifications to methodologies. We will continue to raise this with Ofgem and the UK Government and push for a fairer solution that recognises the renewable capability of Scotland.

Common sense doesn’t seem to enter into any of this. The next section talks about security of supply, but doesn’t begin to address the problems. Instead, counter-factually and almost incredibly:

We believe that onshore wind can play a greater part in helping to address the substantial challenges of maintaining security of supply and network resilience in a decarbonised electricity system.

Conclusion

Reality doesn’t intrude. Instead:

Deployment of onshore wind is mission-critical for meeting our climate targets.

So that’s that. Needless to say, I disagree profoundly.