Onshore wind - policy statement refresh 2021: consultative draft

Chapter 4: Barriers to Deployment: Environmental Factors

4.1. Noise

4.1.1. In 1999, the World Health Organisation (WHO) published Community Noise Guidelines (CNG), and in 2009, the Night Noise Guidelines (NNG) to determine and assess the impact of noise from various sources. However, there was increasing public concern despite a lack of empirical evidence linking any health impacts to noise generated by onshore wind turbines.

4.1.2. In 2010, WHO was requested to produce noise guidelines for a variety of issues, such as transportation, personal electronic devices and wind turbines, by the Member States in the European Region, which was published in 2018.

4.1.3. The WHO report concluded that there was not enough evidence at that time to make any specific recommendations for wind turbine noise, including amplitude modulation, and found no correlation between wind turbine noise and adverse health impacts. It did, however, suggest that policy makers should implement suitable measures to reduce noise exposure from wind turbines in the populations exposed to levels above the guidance (i.e. 45dB).

4.1.4. The WHO report also stated that the number of people exposed to wind energy development noise was significantly lower than that of other sources of noise (e.g. road traffic noise), and therefore estimated that the burden of on health at population level is low. However, it was clear that proper public involvement, communication and consultation, among affected citizens living in the vicinity of wind turbines whilst applications that are being considered, remained essential.

4.1.5. ClimateXChange also published a report on these issues in 2013, having been commissioned by the Scottish Government to review available academic literature on the health impacts of wind farms. ClimateXChange also worked in partnership with campaign group 'Scotland Against Spin' and independent acousticians to understand the extent to which the anticipated impacts of wind farm developments predicted by environmental assessment (including noise) compared to the actual impacts experienced once the wind farms were operational. Neither report showed correlation between the noise produced by wind farms and ill health.

4.1.6. 'Assessment and Rating of Noise from Wind Farms, 1996', known as "ETSU-R-97", is a comprehensive guidance currently used by decision makers across the UK to assess wind turbine noise emissions. ETSU was originally designed for individual turbine sites (characteristic of 1996).

4.1.7. The Institute of Acoustics (IOA) 'Good Practice Guide to the Application of ETSU-R-97 for the Assessment and Rating of Wind Turbine Noise' was published in May 2013. However, there have been significant advances since 1997 in both turbine technology and methods of measuring sound. Additionally, ETSU-R-97 does not currently take amplitude modulation into consideration, supporting the view that this guidance is no longer fit for purpose.

4.1.8. The Scottish Government is committed to ensuring that Scottish citizens are safe, and their health protected, from any potential impacts from wind turbines, or any other development.

4.1.9. We are aware that the UK Government has been considering the extent to which ESTU-R-97 may require updating to ensure it is aligned with the potential effects from more modern turbines. The Scottish Government support this move and anticipate the results of a short-term review project shortly.

4.2. Net Zero and Other Land Uses

Land Use

4.2.1. We are aware of the varying demands on land-use in Scotland and that a balance must be struck to best serve our net zero targets. Our Land Use Strategy, published in March 2021 stated:

"Our land contributes to climate change mitigation in many ways. Scotland has a long and positive history of harnessing renewable energy and our capacity to generate it will need to be increased to meet our net zero targets. Our energy will continue to be provided by a wide and diverse range of renewable technologies, including onshore wind. We will need to continue to develop wind farms, in the right places, and also look to the extension and replacement of existing sites. As set out in our Onshore Wind Policy Statement, in order to achieve this developers and communities will need to work together to ensure that projects strike the right balance between environmental impacts, local support, benefit, and – where possible – economic benefits for communities, for example through community ownership or other means...

As Scotland moves towards being 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 and onshore wind generation, and the protection and enhancement of habitats and biodiversity."

Peatlands and Carbon-Rich Soils

4.2.2. Scotland's natural capital is one of our greatest assets and is central to our future net zero economy, developing thriving rural economies that utilise both peatland restoration and sustainable energy.

4.2.3. Given the vital role that onshore wind and peatlands will each play in tackling Scotland's carbon emissions, it is imperative that we strike the right balance when it comes to their land use and, wherever possible, their interdependencies.

4.2.4. Scotland's peat soils cover more than 20% of the country and store around 1600 million tonnes of carbon. However, it is estimated that over 80% of our peatlands are degraded. When degraded, peatlands no longer provide these benefits and can often emit more carbon than they remove, resulting in the need for suitable management or restoration.

4.2.5. The Scottish Government has consistently made clear its view that the restoration and maintenance of peat and carbon-rich soils is crucial if we hope to achieve our carbon emissions reduction targets. As of March 2020, over 25,000 hectares of peatland have been put on the road to restoration, however we know that more needs to be done.

4.2.6. Our original target to restore 50,000 hectares of degraded peatland by 2020 was updated in the recently published Climate Change Plan Update, aiming for at least 20,000 hectares of restoration per year, with the challenge of restoring 250,000 hectares in total by 2032. Alongside these challenging targets, the Scottish Government has also committed to a £250 million ten-year funding package aimed at supporting protection of these significant carbon stores, and restoring wetland habitats.

4.2.7. To deliver on the 2032 emissions reduction envelope, annual peatland restoration needs to be far higher than the current 20,000 hectare annual target. However, great strides have been made in recent years and the energy sector contributes significantly to the peatland restoration work taking place across Scotland.

4.2.8. The onshore wind sector in Scotland has made remarkable advancements over the past decade in mitigation and restoration solutions for peatland, with environmental agencies and the renewables sector working together to update the good practice guidance for the construction of wind farms in 2019.

4.2.9. Scotland's onshore wind sector can bring many and considerable benefits to rural areas, ranging from the delivery of jobs and investment, restoration and protection of our natural habitats. The Scottish Government is keen to see that the onshore wind sector continue to embrace the opportunities presented by peatland restoration and the challenge of biodiversity loss, showcasing considered schemes that will protect and enhance environmental conditions and peatland restoration.

4.2.10. We consider the identification of the condition of existing peatland to be a vital part of the wind farm design process, and are encouraged to see that this has become standard practice across the sector. We are also optimistic that many developers engage in an open dialogue with land management as early as possible, ensuring that appropriate, site-specific solutions can be deployed.

4.2.11. The variety of measures that can be included within wind farm design to improve degraded peatland have continuously developed as the industry has matured. Peat restoration and enhancement, being developed in tandem with improving habitats for important and protected species, allows projects to deliver multiple positive benefits to biodiversity and the natural environment.

4.2.12. As committed to in the Climate Change Plan, the Scottish Government will explore the development of a Peatland Restoration Standard to ensure best practice and continuous development in the success and effectiveness of peatland restoration. The onshore wind industry has long since committed to the improvement and restoration of peatland on their sites, and the Scottish Government anticipates that the aforementioned standard will be incorporated fully in these processes.

Forestry

4.2.13. In February 2019 the Scottish Government published Scotland's Forest Strategy, covering the decade from 2019 to 2029. This presented a long-term framework for the expansion and sustainable management of Scotland's forests and woodland. This document specifically noted the role of Scotland's forests in Climate Change mitigation and in achieving the ambitions set out in the Paris Agreement.

4.2.14. 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 tones 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 last year's 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.

4.2.15. Where native woodland is planted, this can provide additional benefits for biodiversity by creating new habitat and connecting woodland remnants. While these woodland creation targets will help deliver additional carbon reductions, the existing resource must also be managed sustainably to preserve Scotland's carbon sink.

4.2.16. Scotland has a strong presumption in favour of protecting as well as expanding our forest and woodland and make sure that our forests are sustainably managed. Woodland removal should be kept to a minimum and where woodland is felled, it should be replanted. The Scottish Government only supports woodland removal where it would achieve significant and clearly defined public benefits. In some cases compensatory planting may form part of this balance. This position is detailed in the Scottish Government's Control of Woodland Removal Policy.

4.2.17. "Keyholing", where smaller areas of forestry are removed directly surrounding wind turbines, has been in use for many years and can prevent the need for clear-felling on wind farm sites. The trend towards increased turbine tip-heights for onshore wind turbines may offer further opportunities to exploit this option as clearance between forestry and turbine blades will likely be higher.

4.2.18. Delivering our net-zero ambitions will require the restoration of Scotland's peatland and reforestation in line with Scotland's Forest Strategy, as well as significant and increasing deployment of onshore wind – meaning that we must strike a balance between these areas in Scotland. We believe that co-existence is not only achievable and desirable, but will become increasingly essential over the next decade - with collaboration and innovative approaches on these issues likely to improve Scotland's overall net zero offering.

4.3. Biodiversity

4.3.1. Delivering both our emissions reduction targets as well as our wider national priorities for the environment and land use will require us to conserve and enhance biodiversity, protect conservation habitats and species while generating enough green electricity to support our economy and deliver our binding net zero target.

4.3.2. The Scottish Government published the '2020 Challenge for Scotland's Biodiversity' in 2013, setting out Scotland's ambitions for the conservation and enhancement of biodiversity in Scotland. The more recently published Climate Change Plan update, describes an ambition to develop thriving economies based around woodland creation, peatland restoration and biodiversity as well as sustainable tourism, food and drink and energy.

4.3.3. Securing positive effects for biodiversity is one of six statutory outcomes for the National Planning Framework. The Scottish Government commissioned research from NatureScot to inform the approach to NPF4. A working group was convened to further explore options and emerging themes with a final meeting held in July. This work helped inform the draft NPF4 which will shortly be laid in Parliament.

4.3.4. While onshore wind will remain an essential part of our energy and climate change effort, there may be some conflicts arising between its deployment and nature conservation at a local level. Nevertheless, as the rate of deployment increases in the coming years, we see a great opportunity for wind energy developments to further contribute significantly to our biodiversity ambition by safeguarding intact habitats, restoring degraded areas and improving connectivity between nature rich areas in order to meet our climate change targets.

4.3.5. We have already seen great progress in biodiversity protection and enhancement in operational wind energy sites, including the 2018 "Protect, Restore, Enhance" report from SSE which detailed key examples of improving biodiversity in sites across Scotland, such as enhancing golden eagle conservation in Inverness. Evidence shows significant positive effects on biodiversity from wind farm developments, and this should continue, aligned with future policy on securing positive effects for biodiversity through NPF4.

4.3.6. Wind Europe published 'The Role of Wind Energy in Wildlife Conservation' in 2017, and SEPA and NatureScot have also published detailed guidance on the design and management of wind energy sites. The aim of all of this is to enable the protection and enhancement of local biodiversity, ensuring that wind energy can be deployed in harmony with, rather than at detriment to, the essential protection and regeneration of our natural environment.

4.4. Landscape and Visual

4.4.1. The landscape and visual impact of wind turbines, and how this can be understood both for an individual proposal and in concert with other existing and proposed developments, remains an evolving area.

4.4.2. Scotland's most cherished landscapes are a key part of our natural and cultural heritage and must be afforded the necessary protections. However, we also recognise that climate change, and our net zero ambitions, require decisive action, will change how Scotland looks and that we will need to deploy significant volumes of onshore wind generation over the next decade to help us meet our challenging legal obligations. This is likely to comprise modern, efficient turbines which will maximise the generation possible at each site and a mix of current technologies and taller turbines.

4.4.3. Developers are encouraged to discuss with planning authorities appropriate sites for wind turbines at an early stage with reference to the adopted local development plan. There is also detailed guidance available to assist developers; ensuring wind farms are represented fairly and accurately in applications.

4.4.4. The Scottish Government is committed to continuing to work with all parties involved to reduce any unnecessary barriers to deployment.

Barriers to Deployment: Environmental Factors - Consultation Questions:

11. What are your views on the integration of taller turbines in forested areas?

12. Can you provide best practice examples for effective peatland restoration (with carbon benefits) alongside the development of onshore wind?

13. What, if anything, is not currently reflected in the good practice guidance for constructing windfarms, in relation to building on peat and other carbon-rich soils?

14. From your own experience what can wind farm developments offer in terms of protecting and enhancing the natural environment, in particular through the planting of trees to compensate for those lost during windfarm development and through peatland restoration?

15. Can you provide best practice examples of encouraging biodiversity protection and enhancement, including connectivity between natural areas in wind farm sites?

16. What is your organisation doing to go above and beyond when it comes to biodiversity protection, conservation and enhancement in wind energy development sites?

17. How can habitat management plans better balance protection of the environment with connectivity and the operation requirements of a site?