Tuesday, 29th December 2009
The Royal Society of Edinburgh Inquiry into Facing up to Climate Change
1/ DEVELOPERS MUST FUND ENVIRONMENTAL OBJECTORS
One of the most significant problems we face when addressing the issue of a wind farm or any other major environmental proposal is the current system designed to assess the potential impact that such a development may have on both the land and local community. The existing Environmental Impact Assessment (EIA) Directive gives the developer the responsibility of conducting the assessment and then gives the local authorities the task of evaluating these findings. Given that the UK has a considerable number of scientific experts with the ability to provide information relevant to the potential impact it seems incongruous that the onus of assessing impact lies to such a great extent with the project’s developer. After having invested a great deal of time and money into a potential project, there is a clear tendency for developers to present Environmental Impact Statements that come down in favour of the development, based on the evidence of their own experts (for whom, all-too often, the American author, Upton Sinclair’s observation appears to be relevant, "It is difficult to get a man to understand something when his salary depends on his not understanding it.").
To make things worse, the local authorities themselves often lack the essential scientific expertise to determine any potential project as damaging or counter-productive. Consequently, local authorities rely heavily on the relevant official bodies to make specialist observations about the development proposal on their behalf. However, these official bodies are currently handling large numbers of wind farm cases. This workload raises the question of their capacity to manage any particular case comprehensively and within the planning timescales involved.
Establishing the likely impacts of a windfarm development is generally an expensive process. Responsibility for the EIA process is thus placed on the developer, because normally the developer has access to the necessary levels of funding for such work. Unfortunately many EIAs produced by developers are woefully inadequate. In such cases, the people most directly affected by the potential impacts – i.e. the local community - can rarely afford to present their own view of the potential impacts. This means that the people most affected by a development have the smallest voice in the planning process. This unfair balance built into the EIA procedure really ought to be addressed. Local communities cannot compete financially with developers. This is particularly so with local rural communities, the very places where developers want to construct projects such as wind farms. The information guiding the decision-making process – and thus the power, driving this process - currently lies with city investors, big developers and local authorities, the very people who won't be directly affected by the proposals.
So what is the solution? Local communities, it seems, need to be given a stronger voice in the assessment of any development which would significantly affect their local area. Indeed there is an EU Directive that says as much (the Aarhus Directive).
It seems that some form of fund should be provided which can be used by the local community to create their own EIA if necessary. This would guarantee further examination of assessments already carried out by local developers to ensure a full investigation of any proposed development. A supplementary or alternative assessment carried out by a local community might include reviewing the EIA information, several days’ field work, collating the field data, writing the report and even appearing as an Expert Witness at a Public Inquiry. It might involve investigations into potential peatland impacts and impacts on ecosystem services, but it may also be necessary to consider the site's archaeology, water quality, noise and ornithology.
However, if such work were to be supported from public funds it could consume significant amounts of public money. The funds could instead be created through a bond given from the developer to the local authority at the start of the project in much the same way as a bond is often a condition of planning in respect of any restoration work required at the end of the working life of a development. This new ‘local community bond’ could instead be applied to the initial planning application, and made available to local communities to undertake their own impact work, if they felt it to be necessary. If the community is content with the developer’s EIA, the bond would then be returned to the developer on grant of planning consent. The size of the bond could be based on both the physical scale of the development and also the anticipated economic scale of the proposal as a whole.
Not only would this enable the local community to contribute in an active way to any development proposal, it also has the added benefit of encouraging developers to research thoroughly the implications of such proposals in the first place, and thus produce good EIA documents which local councils, local people and official bodies would be happy to accept without further investigation. This would encourage a win-win situation whereby developers produce high quality EIA documents and local communities feel content that the documents considered by the planning authorities adequately represent their concerns. In so doing, it also therefore has the potential to reduce the current time-consuming, costly and conflict-ridden system presently in place, while actively helping to involve those who at the moment feel disenfranchised by the planning process.
2/ NATIONWIDE ZONING FOR RENEWABLES
Plans to develop 6 wind farms on the remote Dava Moor near Grantown on Spey will lead to the construction cumulatively of over 100 giant turbines, making the overall development one of the largest windfarms in Europe. These projects represent yet another ill-considered nail in the coffin for Scotland’s pristine landscape heritage and will lead to the wanton destruction of a spectacular wilderness site and its transformation into an industrial wasteland. The rape of Dava Moor, like other similar violations of our countryside across Scotland, has been perpetrated by power companies and landowners seduced by the lure of rich returns through over-generous ROCs. They have found willing and compliant allies in the teeming ranks of politicians and planners who leap on the climate change bandwagon without first comprehending the negative impact of their decisions.
If planning consent is granted to the six windfarms at Dava Moor it will destroy a vast peat bog which is up to 4 metres deep and over 2000 years old. It will release massive quantities of CO2 into the atmosphere and disturb the fragile ecosystem and hydrology of the lower regions of the Findhorn River. This fabulous part of our Scottish landscape heritage, home to capercaillies, golden eagles, ospreys, buzzards, red throated divers, lapwings, skylarks and ravens, will be permanently disfigured. This is not the way forward. It is a corruption of the fight against climate change and a disaster for Scotland.
For example, windfarm projects such as the one at Whitelee, south of Glasgow, have led to 633 hectares of trees being torn up and 22 square miles of deep peatland destroyed, to build Europe’s biggest wind farm, with 90km of associated roads to service 140 giant turbines. Forests and peat bogs are natural carbon sumps. Destroying them is like destroying our global air conditioning system. It is the Scottish equivalent of cutting down rain forests in the Amazon and it is unforgivable.
Of course renewable energy is important and of course it will play a vital role in our effort to cut CO2 emissions and reach the targets set by the EU and by the Scottish government. But renewable energy projects must be carefully planned and implemented and must be part of a coordinated package aimed at reducing CO2 emissions. We cannot simply rush headlong into granting approval to windfarms from one end of Scotland to the other. If we are serious about tackling climate change, we need to restore ecosystems and place a value on the ecosystem services provided by our forests, peat bogs, rivers, oceans and soils. We need to pursue a rigorous plan of habitat recovery, delivering environmental improvements, including conservation of biodiversity, water and soil.
It is naïve for the Scottish Government to pretend that forests of giant wind turbines dotted across Scotland’s unique landscape can meet these criteria. The Scottish wind industry is currently struggling to reduce costs of electricity generation from 9p to 8p per unit, even before the subsidy for the renewable obligation certificate (ROC) is taken into account and that adds a further 5.5p per unit. Compare this to the price of nuclear generated electricity in France, currently costing around 1.7p per unit and virtually CO2 emission free and you begin to get the picture.
Solar, wind, hydro, geothermal, wave, tidal and biomass all have a role to play and Scotland, with its lengthy coastline, cutting-edge technology and world-beating scientists can become a global leader. But any diverse energy basket aimed at reducing CO2 must include nuclear. The SNP government are determined to use their planning powers to block the construction of new nuclear plant in Scotland, while relying on imports of nuclear generated electricity from our neighbours south of the border!
It is also the case that the load factor on wind turbines in Scotland is around 28%. This means that we must rely on baseload backup energy production to make up for the shortfall created by an over-reliance on on-shore wind. In the absence of nuclear plant, such baseload backup in future will have to come from fossil fuel gas or coal plants which are high CO2 emitters, thus calling into question the viability of the entire strategy.
It is essential that Scotland should follow the example of other EU Member States such as Germany, by co-ordinating a carefully planned zonal strategy for the construction of renewable energy projects. Local planning authorities should be required to zone areas where wind farms, carbon-capture and storage facilities, nuclear, gas or clean-coal plants could be constructed. Such plans should also clearly indicate where no such projects could ever be entertained under any circumstances. Armed with such detail, the Scottish Government, power companies and landowners would have a clear understanding of where it would be possible to apply for planning approval and where it would be pointless to do so.
