Onshore wind: policy statement 2022

Chapter 7: Onshore Wind and Technical Considerations

7.1. Abnormal Loads and Police Escorts

7.1.1. As we increase the volume of onshore wind in Scotland, and see the real and tangible benefits of this, 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.

7.1.2. 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.

7.1.3. 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.

7.1.4. To this end, the Scottish Government is working directly with senior members of Police Scotland and the renewables and haulier industries. We have come together to consider this issue and to determine what actions must be taken, both short term and long term, to relieve the pressure on Police Scotland resources to ensure turbines components can be efficiently and effectively conveyed to site. This is being undertaken through a series of working groups:

• Practitioners Group
  (Scottish Government, Police Scotland, SR, OEMs, RUK, Hauliers)
• Stakeholders Group
  (Scottish Government, Police Scotland, SR, RUK)
• Abnormal Loads Legislative Reform (ALLR) sub-group
  (Scottish Government, Police Scotland, SR, RUK, Legal representatives)

7.1.5. Following the 2004 amendment to the Road Traffic Act, Traffic Officers have powers to stop and direct vehicles on public roads in England and Wales. Such an approach could help in alleviating the pressure on Police Scotland, but any proposal to broadly mirror this approach, would cover a relatively complex legal landscape with a number of legislative competency boundaries which are untested in this regard.

7.1.6. To further consider this complex issue, the Scottish Government have formed 'The Abnormal Loads Legislative Reform Sub-group', in collaboration with Scottish Renewables and Police Scotland. The group is exploring potential options for legislative change in Scotland to allow abnormal loads to be moved more efficiently. This will be a potentially complex and time-consuming process which will have implications and benefits far beyond the transportation of wind turbine components.

7.1.7. One of the first actions of this group has been to produce an Abnormal Loads Fact Sheet which establishes the current legal position and answers some common questions and misconceptions. This will ensure all impacted parties have the same understanding and will prevent duplication of effort. A copy is available in Annex 6, and the minutes and other documentation relating to this group can be accessed on the Scottish Renewables website.

Abnormal Loads and Oversail Considerations

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

7.2. Background to Eskdalemuir

7.2.1. Eskdalemuir Seismic Array is a seismological monitoring station in the Scottish Borders which forms part of the UK's obligations under the Comprehensive Test Ban Treaty.

7.2.2. 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.

7.2.3. In May 2005 the Ministry of Defence (MoD) issued a technical site direction with a safeguarding map to relevant planning authorities in England and Scotland as well as Scottish Ministers. This direction 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'.

7.2.4. 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.

7.2.5. The 2005 Styles Report recommended a limited budget of 0.336 nm of seismic disturbance would prevent the array's operation being comprised. This was followed by the 2014 work undertaken by Xi Engineering on behalf of the Eskdalemuir Working Group, which developed a spreadsheet tool enabling the MoD to monitor this budget.

7.2.6. The 0.336nm budget was issued on a first come, first served basis and no project has been allocated budget since 2018 due to insufficient budget availability for the next project in the queue. Any additional applications received following this were added to a 'waiting list' for MoD approval.

7.2.7. Unlocking potential capacity will require decisive and meaningful action from the Scottish Government, UK Government and MoD. To do so, we must recognise:

• Safeguarding of the array lies within the MoD policy remit.
• Maximisation of renewable energy deployment lies within the Scottish Government policy remit.

7.2.8. We are aware that the MoD's policy for budget allocation is due to be reviewed and the Scottish Government remains engaged with MoD as they determine next steps for developing policy on this matter.

7.2.9. Looking to Scottish Government policy, through a series of technical evaluations and studies, we identified that the algorithm used by the MoD to calculate the budget takes a conservative approach and, by design, over-estimates the seismic contribution of each wind turbine.

7.2.10. The Scottish Government are engaging with MoD to approve the data collected and are seeking agreement that MoD will adopt this evidence-based approach and adjust the calculation for budget utilisation.

7.2.11. It is important to note that, if MoD do accept the findings of these technical studies, the limited 0.336nm budget will remain unchanged.

7.2.12. Following these conversations and reflecting on the results of the recent draft Onshore Wind Policy Statement consultation, as well as the multi-phased technical work, we intend to finalise our approach to maximising renewable deployment within the 50km consultation zone as soon as possible following of the publication of this statement.