Scottish Government

Scottish Power's letter of 22 March 2006

Dear Ian

Scottish Executive ( EAFRE): Consultation Draft SPP6

Thank you for this early opportunity to comment on the Consultation Draft of SPP6.

We have marked up the document in 'track changes' and attach a separate sheet explaining the rationale behind any proposed deletions of text.

We welcome the positive approach to renewables planning policy guidance and particularly welcome paragraphs 2, 11 and 24.

We would like to take this opportunity to explain our thoughts on the following five key issues:

1. Site Selection

You will note that we have suggested amendments to paragraph 7 and we have essentially drawn from existing guidance published by SNH in their document ' SNH Policy Statement 01/02: Renewable Energy' (par 48, 3 ^rd bullet).

These principles of site selection should be utilised throughout the document and should focus development on:

• development of windfarms in 'developed' landscapes and brownfield sites (including those already subject to mineral extraction or commercial forestry);
• development of large sites in areas of low landscape sensitivity and existing infrastructure (i.e. roads and grid)
• development of extensions to existing projects; and
• 'replanting' aging technology.

2. Methodology for Targets

The proposed approach to targets is set out clearly in the first sentence of paragraph 36. It would be useful to have this reiterated at the front of the document.

To avoid local authorities taking an ad-hoc approach to the setting of targets, it would be useful for the Scottish Executive to set out a methodology. This should include a standardised approach to capacity assessment, consultation with neighbouring authorities and the Executive's Consents Unit.

3. Grid

We understand the intention of the Scottish Executive in attempting to draw renewables development and associated grid infrastructure work together. However, there are fundamental issues associated with this that would make such an approach very difficult to implement.

In our extensive experience, grid connection offers and any design work associated with proposed grid connections almost never runs concurrent with the planning process. It is for this reason that we have suggested that the last sentence of paragraph 50 be deleted.

We also understand that the Scottish Executive is keen for the renewables development industry to utilise existing infrastructure where possible. It is for this reason that we have suggested the second bullet point of paragraph 7 which states that during site selection, larger projects should be guided to areas of existing grid infrastructure.

In essence, we are suggesting that grid capacity will certainly be a consideration in setting of targets and site selection. However, the ability to utilise existing grid infrastructure should not be a material consideration in the determination of an application.

We encourage the efficient use of the grid system but also acknowledge that windfarm developments are currently being progressed in areas where no (or limited) grid capacity exists at present. Such projects may have an essential role to play in providing justification for regulatory support for the associated transmission upgrades that in turn will be critical for the development of the marine renewables industry.

4. Preferred Areas

The requirements of SPP6 to identify preferred areas are noted. The concerns we have are that such an approach can be flawed as no-one has access to perfect information.

We have amended paragraph 42 to essentially suggest that instead of allocating 'yes' areas and 'no' areas, the following guidelines are used:

• Identification of preferred areas, where there would be a presumption in favour of development;
• Areas where there are no significant constraints and that are safeguarded for future development; and
• All other areas where development will be considered on its merits, subject to certain criteria. In practice these 'other areas' will be protected by parallel legislation including designated nature and landscape designations.

5. The Planning etc (Scotland) Bill 2005

The forthcoming Planning etc (Scotland) Bill 2005 will play a key part in the implementation of this SPP including the proposed additional consultation (paragraph 6, last bullet point) and the proposed notification of applications (paragraph 51).

During our submissions on the Planning etc (Scotland) Bill 2005 we have queried the level of resources available to implement such radical proposals and we would reiterate our concerns here. The requirement to set targets and to permit inter-authority working will require extra resources and additional skills.

I would be happy to discuss any of our suggested amendments with you direct. Please do not hesitate to request a 'phone call or meeting if you think this would be of use.

Yours sincerely

Andrew Jamieson
Head of Renewables Business Development

cc. Wilson Malone, Scottish Executive

Encl.

Rationale for Recommended Deletions

12. This statement implies that renewable development would not be the preferred option for development in a given area. The words "… taking account of other priorities in the area" should be deleted.

14. The first two sentences should be deleted as they simply seek to differentiate between technologies.

26. In addition to para 25, para 26 should be deleted. The definition of a 'community' is assumed to be helpful but would only lead to future debates on the interpretation of the definition. The closest residential properties are normally assessed for a variety of potential impacts as part of an Environmental Impact Assessment.

31. The suggestion that each preferred area has its own MW cap, beyond which there is a presumption against, will end up being hugely restrictive by fractionalising the resource. This is a direct contradiction of the 'no cap' principle in paragraph 2 and the final sentence should be deleted.

34. The third bullet point is surely outside the influence of SPP6 and should be deleted.

37. The last sentence is related to the current scenario, is likely to be superseded as time moves forward and should be deleted.

45. 2 ^nd last sentence, "during the currency of this SPP, the Executive's 6 GW target could be met …" - inevitably, the percentage success rate of these projects will be very small and this sentence should be deleted.

50. The last sentence states that grid information should be made available with the application. This information is not often available at the same time and should not be requested as part of any application. The last sentence should be deleted.

51. This advice would be impossible to implement and should be deleted. One never knows what will be submitted into the planning system. However, the Planning etc (Scotland) Bill 2005 is seeking to introduce a 'notification of application' and this may contribute towards this debate in the future.