7.3 Energy & Climate Change Policy & Legislative Requirements
7.3.1 The urgent need for offshore wind has been set out: a large increase in the deployment of this renewable energy technology is supported through a number of policy documents and by Scottish Government commitments – specifically within the Offshore Wind Policy Statement.
7.3.2 The declaration of a Climate Emergency needs to be viewed in the context in which it was declared and what followed from it as a result of the declaration. The declaration was a reflection both of the seriousness of climate change and its potential effects and the need for urgent action to cut carbon dioxide and other greenhouse gas emissions. It means action now and not next year or the year after that.
7.3.3 The drive to attain net zero emissions is now legally binding at the UK and Scottish Government levels by way of amendments to the Climate Change Act 2008 and in Scotland with the provisions of the Climate Change (Scotland) Act 2009 and the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019. Scotland’s 2030 interim emissions reduction target is highly challenging. The Project would be a major single step forward in ensuring that the target can be attained.
7.3.4 The climate emergency is not just a consideration, it is a factor of considerable importance. It adds significantly to the weight of positive support in the balance in this case. The need for the Project should be afforded substantial weight in the planning balance. The way that decision makers can do that is by properly recognising the seriousness and importance of energy policy related considerations in the planning balance. It is the cumulative effect of a large number of individual renewable projects which will move Scotland towards where it needs to be. The size and scale of Berwick Bank means that it moves Scotland significantly closer to that in a single step.
7.3.5 The Statement of Need also explains the important energy security and affordability benefits associated with developing electricity supplies which are not dependent on volatile international markets and are located within the UK’s national boundaries. The urgency for an electricity system which is self-reliant and not reliant on fossil fuels is enormous in order to protect consumers from high and volatile energy prices, and to reduce opportunities for destructive geopolitical intrusion into national electricity supplies and economics. The Proposed Development would make a significant contribution towards the UK attaining these security of supply and socio-economic objectives.
7.4 Policy Assessment
7.4.1 From consideration of all of the predicted environmental effects of the Proposed Development and, where relevant, compensation measures proposed, residual significant environmental effects are considered to be very limited. When considered in the context of the relevant policy and legislative considerations, it is clear that the Proposed Development, on the whole, meets the relevant policy requirements which in summary are aimed at, increasing renewable energy capacity, whilst minimising effects on human health, minimising wider environmental harm and ensuring that conflicts with other users of the marine environment are kept to a minimum.
7.5 Overall Conclusions
7.5.1 There has been a significant degree of consultation and a carefully considered design and mitigation approach has been followed. Whilst there are some significant effects identified these are limited in the overall context and range of effects arising. Moreover, the most significant effects are compensated for via a well-developed and deliverable programme of measures.
7.5.2 Overall, it is considered that there is accordance with legislation and policy in terms of increasing renewable generation and capacity and minimising conflict with users of marine environment, human health and environment.
7.5.3 A worst-case scenario approach has been assessed and appropriate mitigation has been proposed and can be secured to address any residual effects. The MPS makes it clear that there is a balance to be struck between benefits and reported likely adverse effects.
7.5.4 It is considered that the overall policy appraisal presented in this submission demonstrates a compelling case that Berwick Bank would deliver significant benefits in the wider public interest. The Project has been designed and assessed in full accordance with relevant legislative requirements and the underlying aims and objectives of policy framework.
7.5.5 Berwick Bank as one of the largest offshore Wind Farms being proposed in the world, can substantially contribute to both the Scotland and the UK’s legally binding climate change targets by helping to decarbonise energy supply, whilst also contributing to the essential tasks of ensuring security of supply and providing low-cost energy for consumers in line with the Scotland and UK Government’s national policies.
7.5.6 Berwick Bank will also contribute materially to the economic and social landscape in Scotland and the UK as it can provide substantial employment opportunities and skills development, particularly in coastal communities, whilst also playing a major role in supporting Scotland and the UK’s supply chains.
7.5.7 It must follow from the above that the benefits that would arise from the Project should be afforded substantial weight in the planning balance. The delivery of this renewable generating infrastructure will substantially assist in the delivery of the Net Zero policy imperative, by the critically important date of 2030.
7.5.8 Consideration of the application will involve striking a balance between the need for the Project, its benefits and the mitigation of and compensation for predicted environmental effects. The benefits of the proposed development significantly outweighed its adverse effects.
7.5.9 For the above reasons it is recommended that Section 36 consent and Marine Licenses should be granted.
David Bell Planning Ltd
26 Alva Street
Edinburgh
EH2 4PY
dbplanning.co.uk
© David Bell Planning Ltd Copyright 2022
[1] Based on ScotWind Results: scotwind-list-of-successful-project-partners-170122 (crownestatescotland.com)
[2] Option Area W1 (2 GW – fixed) and Option Area N1 (2 GW – fixed). Option Area NE4 has indicative capacity of 1 GW scotwind-list-of-successful-project-partners-170122 (crownestatescotland.com). However Caledonia Offshore Wind Farm Scoping Report (Option Area NE4) pre-application_-_offshore_scoping_report_redacted.pdf (marine.gov.scot) refers to target capacity of 2 GW.
[3] Scottish Power Renewables (SPR) – connection location not stated (ESO Data Portal: Transmission Entry Capacity (TEC) Register - Dataset| National Grid Electricity System Operator (nationalgrideso.com)
[4] West of Orkney Scoping Report (OWPL, March 2022) makes reference to both fixed and floating foundations Scoping Report (marine.gov.scot)
[5] Based on Typical Domestic Consumption Vales (Medium Electricity Profile Class 1, 2,900kWh per household: OFGEM, January 2020), minimum projected 50% load factor, and projected installed capacity of 4.1GW.
[6] Source: CCC (2022).
[7] Scottish Government, Official Statistics, Scottish Greenhouse Gas Emissions 2020, (June 2022).
[8] Department for Business, Energy & Industrial Strategy, 2021 UK Provisional Greenhouse Gas Emissions, National Statistics (March 2022).
[9] Department for Business, Energy & Industrial Strategy, UK Energy in Brief, National Statistics (2022).
[10] Scottish Government, Energy Statistics for Scotland, Q1 2022 Figures (June 2022).
[11] Based on Typical Domestic Consumption Vales (Medium Electricity Profile Class 1, 2,900kWh per household: OFGEM, January 2020), minimum projected 50% load factor, and projected installed capacity of 4.1GW.