Sharing Good Practice - Onshore wind repowering 7 th December 2017 - - PDF document

Sharing Good Practice - Onshore wind repowering 7th December 2017 Summary and key messages Introduction This note captures the key messages from the Sharing Good Practice event on repowering held at Battleby on 7th December 2017. The event was attended by over 80 people from a mix of planning, consultancy, developer and NGO backgrounds. This note does not capture all of the points raised – it is a summary of key

• messages. It does not summarise the presentations given – these are available
• here. Note – the note captures the messages shared by attendees at the

event, and does not necessarily reflect the views of SNH. We plan to consult on draft guidance on assessing repowering applications during 2017 and attendees will have an opportunity to comment on our proposals at that stage. Key messages from plenary sessions  Repowering older sites does not negate need for new wind farms, we need both  Onshore wind making a significant contribution to electricity targets in Scotland and is likely to be a key long term energy source  Repowering applications still need to follow the normal planning and EIA process  SPP already sets out some key principles for repowering  Existing scheme a material consideration  There are mixed views on whether a national approach to repowering would be beneficial  Need to encourage innovation to streamline the process and reduce costs  Variation in consenting – some time limited some not  We need a consistent approach to repowering applications  Repowering will take many different forms: life extension, replanting, repowering, geographical extensions  Turbine sizes increasing rapidly  Removal of subsidies driving increase in tip heights as is change in technology  Opportunity to take a more planned approach national / regional / local scale  Scope within existing SPP to plan at the local level  Repowering is an opportunity to improve individual schemes and the wider pattern of development

 Larger turbines will require lighting – a new issue for LVIA  SNH developing guidance on assessing applications and keen to engage in dialogue about this  Some new issues to be addressed: survey methods, baselines for assessment  Different approaches unfairly applied to different technologies (eg coal and nuclear)  Need to plan positively for the future of onshore wind  Need for proportionality in the way repowering applications are assessed  Some infrastructure can be re-used, but some not likely to be fit for purpose  Significant opportunities could arise from recycling and refurbishment markets  Very large quantities of material will need to be recycled  We need to rethink the way some infrastructure is designed to facilitate re-use and recycling  SNH and SEPA working with industry to explore new methods for building turbine bases  New technologies coming in to market – repowering schemes likely to include multiple technologies in future to maximise use of grid Key messages from workshops on planning The workshops on the planning system focussed on identifying the main challenges and opportunities associated with repowering. Groups were also asked to identify their ‘key asks’ from the planning system. Challenges  A high standard of EIA is applied to onshore wind – can we reduce expectations ?  Need to determine scope of new EIA required  Cumulative effects, including the impact of small / individual turbines  Larger turbines appropriate in some areas but not others  Need clarity on perpetuity paragraph in SPP  Land ownership patterns have significant influence on pattern of development and scope to improve this  Communities’ expectations are that schemes are consented for 25 years  Need to improve community engagement process and outcomes  Need to consider mix of energy sources in future  Relatively short duration of consents creates challenges for planning process  Grid capacity has significant influence on pattern of development – is a more strategic approach to grid required ?  Route to market is challenging following subsidy removal  Net economic benefits need to be considered in planning process  SPP is quite restrictive on what planning authorities can do  Capacity already reached in some areas  Need for better information sharing with the public on applications, scale of development and the technology itself

Opportunities  Life extension of existing schemes is attractive as it maximises the use of existing infrastructure  Opportunities to reuse existing infrastructure  Scope for greater collaboration both between developers, and between developers and planning system – opportunity to learn from other sectors ?  Better community engagement processes could be developed  Scope to improve some sites to optimising layout / tip heights  Scope to maximise generation capacity and utilise new technology  Opportunity to remove some wind farms which are not well sited  Scope to adopt a ‘masterplanning’ approach to repowering to maximise capacity and to be more proactive in steering development  Visualisation methods improved – scope to look at 3D / Digital next ?  Could we move to a ‘call for sites’ approach as used in LDPs for other forms

• f development ?

 Opportunity to secure additional benefits from Habitat Management Plans  Calls for a national approach to repowering  Woodland creation opportunities on restored sites  Employment opportunities from repowering  Manufacturing / refurbishment commercial opportunities and links to circular economy  Scope to change the way turbine bases are built  Improving efficiency of new turbines will increase output  Opportunity to learn lessons from existing schemes  LPAs can steer development to best locations based on experience  Greater collaboration between developers  Opportunity to secure more benefits from repowering sites, including community benefits Key asks  Don’t be too prescriptive  Greater collaboration  Clarify what is meant by perpetuity paragraph in SPP  Consistent definition of baseline  More resources in planning system  Developers to take head of early advice from planning and statutory consultees  Future proof capacity studies and spatial plans  Take account of need to increase tip heights in light of subsidy removal  Need to think about carbon implications of long term repowering

Key messages from workshops on developing SNH guidance Attendees participated in 4 workshop sessions in the afternoon (one led by SEPA). This note captures the key messages from the SNH led sessions on birds; habitats and ecology; and landscape and visual assessments. Each section includes a summary of what SNH propose and a record of the key points raised in discussion. Attendees were also asked to vote on a key question for each topic. The results of the voting are included here for completeness. Birds Survey and Assessment Methods Summary of proposals SNH proposes that proposed changes within the footprint of the existing wind farm should normally only require a desk-based study. No distribution and abundance surveys are required in the existing footprint because the ground has previously been surveyed for the original proposal and it is unlikely that any significant changes have occurred. Vantage point surveys are not required over the existing turbines. Flight activity would not be representative because the flight activity is affected by the presence of the existing wind farm. Any new collision risks predicted from such work would be inaccurate. However, as part of the desk study, if possible, developers should recalculate collision risks using the original VP data. For proposed changes outside the existing footprint, normal bird survey methods should be followed. Birds may now be using a much smaller area of nearby habitat much more intensively, or activity may be lower due to displacement. New survey will help provide data on this. There may be exceptions – for example no need for new survey if in areas of low bird sensitivity, or if it is a minor extension close to the existing footprint. Discussion 1) Are there alternative methods that could be used to assess repowering applications? 2) Are there any situations where vantage point surveys would be helpful within the existing wind farm footprint?

Key points discussed Terminology  Guidance should define terminology particularly what is meant by footprint and the buffer of the footprint (200m or 500m). Clarity  More clarity needed about what is required as part of the desk-based study (e.g. using Post Construction Monitoring (PCM), noting change of habitat, change of bird species).  Make it implicit in the guidance that there is still the requirement for pre- construction surveys.  Some thought that the guidance may be too broad an approach and more caution is required – suggestions that the guidance should say that the approach taken to survey and assessment methods is site specific and dependent on the quality of PCM. Post-Construction Monitoring  More information on the requirement for PCM and using it to inform repowered site surveys.  Questions raised about sites where no PCM data was collected – or make it more implicit in the guidance that PCM is required on more sensitive sites  Encourage the sharing of PCM data, data from bird groups and the public  Many questions raised about substantial changes in habitat from when baseline surveys conducted for original ES and repowered site (e.g. when deforestation occurs during construction of original site and site changes to moorland) and whether doing new analysis with old baseline data may be inaccurate. General  Why are there inconsistences and opposite approaches in guidance between protected species and birds?  One group believed that conducting surveys to inform the baseline was important as it will at least give a steer on whether more or less survey work is required later on in the process. Some attendees also believed the approach suggested is not adequate for ascertaining distribution and abundance of species.  The guidance could have a matrix of potential impacts and the quality of information required, and then this could inform the decision on which survey methods are appropriate  One idea put forward that PCM may be out of date as only 1,3,5,10 years. Why not have PCM in last 4 years of life (or four years before repowering) so data is more up-to-date?  Need to think about situations where species have been reintroduced

Voting Do you agree that normal distribution and abundance surveys, and vantage point survey are not required within the existing wind farm footprint? The majority of attendees were either neutral or agreed / strongly agreed with the approach proposed, though one group in particular did disagree.

Ecology and Habitat Workshops Summary of proposals The baseline for assessment should be the restored site, as agreed in the Decommissioning and Restoration Plan (DRP) for the original application. For repowering proposals (but not life extensions) there should be new habitat and species surveys following our normal guidance. In some cases, re-surveying of habitats will not be necessary and the survey data from the original ES can be used to inform the baseline – e.g. across lower importance habitats such as farmland. Peat surveys should also reflect the latest guidance. But areas comprehensively surveyed for peat that have not been changed by the existing development, would not need to be resurveyed. The success of habitat restoration for the original scheme should be considered, and the new proposal should aim to minimise any undoing of restoration, and should ideally build upon earlier habitat management. Discussion 1) Should the baseline for assessment be the restored site? 2) Are there new methods that could be used to assess repowering applications? 3) Are updated protected species surveys likely to be helpful? Key points discussed  It is unfair on the developer to expect them to work from a baseline of improved habitats and ecology on site from that of the original state, i.e. following successful habitat management and restoration during the

• perational stage. However, some attendees strongly disagreed with this.

 Requirements for restoration will vary greatly from site to site, and this will influence the baseline.  Forecasting a decommissioning and restoration plan into the long term is difficult  Consideration of the re-use of infrastructure on site is an important aspect of the baseline.  The baseline should be the state of the site just before you start removing the infrastructure at the decommissioning stage (at the start of any repowering proposal), i.e. from a wind farm present starting state.  What is the status of the site following decommissioning – is it a brownfield site? Does the status influence what is determined as the baseline and therefore survey requirements?

 Can we look at demonstration sites (not impacted by development), adjacent to the site (impacted areas), to gauge degrees of habitat change over time, extent of restoration required and to help steer thinking on baselines.  Ongoing monitoring of on-site habitats and ecology should inform the baseline, the survey and assessment requirements, and allow for a greater understanding of the degree of change that is / has taken place. Although, data on this is often sparse.  Interesting to consider the incremental change over several generations of wind farms and defining the ongoing baseline. New methods:  Making more use of aerial lidar.  Using the latest bat survey techniques to minimise collision risk  Any technique that allows the developer to remain compliant with legislation.  Promote more HMP data sharing – sing about success stories – data can have implications for surrounding populations  Innovative methods are not always sufficiently established / robust to provide decision makers with the confidence to approve schemes. Updated protected surveys:  Resurveying for any new proposal should be undertaken, not just relying on

• ld data.

 Survey results have a shelf life.  Legislation, as well as population dynamics change over time.  Not enough use is being made of post construction monitoring data that could inform future generations of wind farm development Voting Do you agree that the baseline for the assessment should be the restored site? There was a fairly consistent view amongst attendees who disagreed with our proposal.

Landscape and visual workshops Summary of proposals SNH proposes that Landscape and Visual Impact Assessment (LVIA) should be carried out for life extensions and repowering proposals as standard. Baseline for assessment For repowering and life extension proposals, the LVIA baseline should be the landscape restored in accordance with any associated decommissioning conditions. Supplementary comparative assessment A supplementary assessment would help decision-makers take account of the current use of the site as a wind farm as a material consideration. This would compare the effects of the new proposal with the existing. Related visualisations The LVIA would include baseline visualisations with the original/ existing wind farm turbines (and associated tracks/ infrastructure) digitally removed. As part of the supplementary comparative assessment, each viewpoint in the LVIA should include an additional image with the existing turbines present, alongside the new proposal. Discussion 1) Are there alternative ways of conducting the LVIA? 2) Should the baseline for the assessment be the original (or restored) landscape? 3) What combination of visualisations do you think are required? Key points discussed  Need to future proof capacity studies, especially on turbine height  Opportunity to evaluate existing sites  Risk of marginal / incremental impacts  The proposed approach is cumbersome in terms of the nature of the assessments and the subsequent volume of documents arising, and is disproportionate to the likely impact that is being assessed  There is a danger that the approach will assess issues that are not relevant to the determination of the re-powering application.  Could a scoping process be used to focus the LVIA on what are likely to be the determining issues, as agreed by statutory consultees.  The focus on the baseline as the restored site may throw up some anomalies. For example at Whitelee Wind Farm there is now an agreed access/recreation strategy to ensure that some of the wind farm track infrastructure will remain

• nce the planning permission has expired, so the site will never be returned to

its pre-development state.  For wind farm sites where commercial forestry was removed across the site, would the baseline be the re-forested site? And would the trees need to be digitally included in the photomontages being asked for?  For some people, the presence of a wind farm is normal, and so the baseline for them would be the landscape with the wind farm in it.  The focus of the LVIA should be analysing any incremental change to the landscape.  There are 3 types of WF development that will each require a different approach to determining what the baseline for assessment is:  sites which have no restoration obligation following removal  sites where there is a restoration obligation  sites permitted since the 2014 SPP ‘in perpetuity’ policy where there would be no restoration of the site because it will be in constant use as a WF.  the word ‘supplementary’ ought to be dropped, otherwise it is likely that the document will be seen as extra and not essential, and therefore not given due regard.  In doing the LVIAs, would the same viewpoints be used as were used in the

• riginal WF? Perhaps the number of viewpoints could be reduced, with a

focus on key viewpoints only in the assessments, as this would be more proportionate.  The consented WF is a material consideration. The decision maker is not deciding whether there should be a WF on the site or not, they are assessing the incremental effect arising from the repowering application as presented. Voting Do you agree with the SNH proposal that the baseline for the assessment is the restored landscape?

Baseline There were mixed views on the baseline for assessment, with more attendees disagreeing with the approach proposed. Visualisations There were mixed views on the suite of visualisations proposed, with slightly more attendees disagreeing than agreeing with the approach. Comparative assessment Most attendees agree that a comparative assessment of the existing wind farm and what is proposed is required