Written evidence submitted by EDF Renewables (RES0009)

Scottish Affairs Committee

Response from EDF Renewables to the Call for Evidence on in

Introduction to EDF and EDF Renewables EDF is the UK’s largest producer of low carbon electricity. We operate low carbon nuclear power stations and are building the first of a new generation of nuclear plants. We also have a large and growing portfolio of renewable generation, including onshore and offshore wind and solar generation, as well as . We have around five million electricity and gas customer accounts, including residential and business users.

EDF aims to help Britain achieve net zero by building a smarter energy future that will support delivery of net zero carbon emissions, including through digital innovations and new customer offerings that encourage the transition to low carbon electric transport and heating.

As a key part of EDF, EDF Renewables is one the UK’s leading renewable energy companies, specialising in , solar and battery storage technology. We are making a substantial contribution to achieving Scotland’s net zero ambitions, with almost 500 MW in operation over eight onshore wind farms and through the construction of the 450 MW Neart na Gaoithe offshore and the 30 MW West Benhar onshore wind farm in North Lanarkshire.

We welcome the opportunity to respond to the Call for Evidence on Renewable Energy in Scotland in the following sections of this document.

Should you wish to discuss any of the issues raised in our response or have any queries, please contact our Head of Renewable Policy & Regulation, David Acres.

1 Executive Summary

The renewable energy sector has been extremely successful in creating jobs in Scotland and in the rest of the UK, with 26,093 employed in the UK offshore wind workforce alone as of December 2020.[1] The renewable energy sector creates roles in skilled, technical and professional jobs, as well as in leadership, corporate and operational management roles, and will make immediate and significant contributions to the Green Recovery.

Targets for renewable energy can play a key role in delivering ‘net zero’. They highlight to key stakeholders the government’s intentions, thereby motivating industry and increasing investor confidence. However, alongside each target there must be a set of supportive policy measures to ensure that the target can be achieved. This in turn should deliver a strong and visible pipeline of future renewable projects that will enable local supply chains to develop. These will bring economic benefits as well as direct job creation.

To enable the pipeline of renewable projects in Scotland to continue to increase and to contribute to the delivery of net zero targets, the following policy measures will need to be a priority for government and regulators:-

Planning consents

Given the urgency of the climate emergency, direction must be given in planning legislation and guidance to have special regard to the need for new low carbon infrastructure, in order to deliver a net zero economy. Ideally a direction or guidance should be introduced ahead of the current timetable for the issue of National Planning Framework 4 (NPF4). Stakeholders, decision-making authorities, local planning authorities and statutory consultees must all be sufficiently funded to ensure they have the capacity to deal with consenting, licensing and regulating of the pipeline of renewable projects needed to deliver targets and meet net zero.

Investment in grid infrastructure

Strategic anticipatory grid upgrades and investment in new infrastructure must be facilitated. This will be necessary to ensure that both onshore and offshore wind projects can be deployed at least cost to the consumer and at the pace needed to meet net zero, whilst minimising environmental impacts. Alongside this it is critical that National Grid ESO also continues to make rapid progress on new services to maintain system resilience enabling progress to net zero.

A Net Zero Duty for Regulators

In addition to setting targets for actions to deliver net zero, EDF believes that the time has come to specify a net zero duty for all regulators. At present there is no explicit, unambiguous direction to regulators to have special regard to climate change and the delivery of net zero. This means that low carbon projects (including new renewable generation), which can make a major contribution to the transition to net zero, may be long delayed, or even frustrated altogether, because undue weight is given to relatively minor and localised potential detriments.

[1] OWIC, Offshore Wind Skills Intelligence Model Report, February 2021

2 Response to Call for Evidence Questions from EDF Renewables

Scotland’s renewable energy targets

1. How effective has the setting of targets been in achieving ‘net zero’ emissions by 2050 (UK Government) and 2045 (Scottish Government)?

EDF welcomed the announcement of Scotland’s net-zero emissions target by 2045, and the UK’s net zero emissions target by 2050, which were amended in both the Climate Change (Scotland) Act and the UK Climate Change Act in 2019. These targets have kept the UK in line with commitments it made in the 2015 Agreement to keep global warming under 2 degrees and sent out a strong message globally, with many other countries following with announcements of their own net-zero targets.

The interim targets and climate budgets provide clear short-term goals, ensuring progress is measured at regular intervals, and additional actions can be recommended if the UK falls short of any interim targets, as this will impact the likelihood of meeting net-zero targets. The Climate Change Committee’s (CCC) recommendations for the UK’s Sixth Carbon Budget, published in December 2020, advised that will need to double by 2050 and that renewable energy generation must quadruple to meet this demand. Whilst the power sector has already decarbonised significantly through the transition away from coal-fired power, this highlights that there is still a significant net zero challenge for the power sector in the years to come.

Whilst targets are extremely important to motivate industry to increase deployment, in isolation they are not enough to ensure delivery. There must be supportive policy and incentives to ensure the necessary level of renewable energy is deployed to meet interim targets, and eventually net-zero targets, in line with the CCC statement that ‘targets would only be achievable if policies are well- designed to reduce emissions across the economy without delay.’1

To date much of the success of decarbonising the power sector can largely be attributable to the combination of the closure of coal-fired generation, a substantial expansion of renewable generation through successful Renewable Obligation Certificates (ROC) and Contract for Difference (CfD) support schemes and (until recently) a supportive planning regime for renewable technologies. As a result of these and other measures, Scotland only just fell short of meeting its target of 100% of electricity consumption to be met with renewables in 2020, and renewable electricity output has almost tripled in the last 10 years, which is a significant achievement.

Scotland must continue to deploy renewable energy at pace in order to continue to meet domestic demand projections, taking account of the opportunities for the electrification of heating and transport. In addition, there are future opportunities for the export of renewable energy to the UK and .

However, there is evidence to show that in Scotland the rate of success for onshore wind farm planning applications following an appeal has reduced considerably since the climate emergency was declared in 2019 and net-zero targets were adopted. This is a concern, especially when combined with evidence published by the CCC in Scotland’s 2019 Progress Report, which shows that Scotland is at risk of missing its interim target of a 56% reduction in emissions by 2020.

In response, the next Scottish Government must ensure the pace of renewable deployment is maintained, as well as prioritising low-carbon heat, transport and energy efficiency, as considerable action is needed to decarbonise these sectors.

1 Committee on Climate Change, Reducing UK emissions, 2019 Progress Report

3 2. What lessons can or have been learned from setting net zero targets?

Setting targets is a good way to highlight to key stakeholders the government’s intentions, however targets need to be revisited regularly and supported sufficiently with appropriate policy measures. Regarding the revisiting of targets, the original Scottish Parliament target for renewable electricity by 2020 was 15%, which was originally regarded as a challenging and stretching target. However, this was subsequently increased up to 100%, with the out-turn result being 97%. If the target had not been revisited as progress was made, then it is likely that a far lower level of renewable electricity would have been delivered in 2020. This illustrates the importance of revisiting targets, to ensure they are always updated as technologies and sectors progress and that appropriate policy measures are updated or introduced to ensure that targets can be met.

As a more recent example, EDF welcomed the timely decision from the Crown Estate Scotland on ScotWind leasing announced in March 2021, as this will ensure the programme for the development of offshore wind sites in Scotland remains on track, in line with the following statement by the Cabinet Secretary or Environment, Climate Change and Land Reform “The Scottish Government’s climate change plan requires a zero carbon electricity system by 2030 – maximising offshore wind’s contribution will be vital to achieving this and therefore is a key priority for this government.”

In the following sections we have summarised the key policy measures and incentives that are needed to ensure the necessary level of renewable energy is deployed to meet interim targets and, ultimately, net-zero targets,

Planning consents EDF Renewables and other developers have experienced significant challenges in securing timely and proportionate planning decisions in recent years. We recognise and support the need for every development to meet the applicable planning and environmental standards. Our concern is that the overall planning process is falling short of the performance that we need to enable the scale of new renewable generation development required to deliver net zero.

It is important that all technologies eligible for CfD auctions have equal opportunity to bid in each auction round, as this will ensure that a diverse and low-cost mix is secured. Current planning delays for some technology categories are an obstacle to guaranteeing this optimum auction outcome. This is particularly an issue for onshore wind projects for which, over the last five years, the average time to navigate the onshore wind planning processes to approval has been 37 months. These decisions could impact projects qualifying for upcoming CfD auctions, reducing the likelihood that Scotland meets its 2030 target of a 75% reduction in emissions.

For these reasons, planning must be an immediate priority for the Scottish Government. In particular, given the urgency of the climate emergency, special regard must be given in planning legislation and guidance and the need to deliver a net zero economy through new low carbon infrastructure. The need for low carbon infrastructure must be given due weight alongside the residual impacts that renewable development may have.

Many currently consented projects will need to be re-consented with the latest turbine technologies in order to maximise their efficiency and competitiveness in future CfD auctions. As emphasised previously, meeting interim targets will ensure Scotland is on track to meet its 2045 net zero target, and therefore immediate action is needed for decision makers to ensure viable renewable projects gain timely consent, both for new applications and variations. A presumption in favour of repowering and extensions of existing wind farms should also be granted.

4 To address these immediate needs, we recommend that interim advice and clarifications are issued ahead of the formal publication of NPF4. More generally, a well-resourced planning system is key to delivery of projects, both in the near and longer term, and is needed to meet net zero. Consideration should be given to actions that speed up the whole decision-making process (such as reducing the number of projects that require Public Inquiry, as well as making Public Inquiries more focussed and timely when they are necessary).

Grid access Grid access and availability is currently another barrier to the development of the renewable generation pipeline, both in Scotland and the UK. Whilst we recognise that action relating to transmission grid infrastructure is under the jurisdiction of the UK Government and the electricity regulator, it is important that a more strategic approach to anticipatory investment is devised across the UK. For example, transmission charges for projects on remote islands must be proportionate to enable positive economic opportunities that renewable energy can bring to island communities.

EDF therefore recommends that an onshore transmission review is carried out, to identify actions that will help deliver the anticipatory investment needed for the timely expansion of onshore technologies across the UK. Alongside this, it is critical that National Grid ESO continues to make rapid progress on new services to maintain system resilience, as this is crucial to enable progress to net zero.

Radar mitigation One further obstacle to renewable development is the cost and complexity of radar mitigation for onshore wind projects. This is a long-term issue which is continuing to constrain development in key areas of Scotland. The cost of mitigation can be 5% of the levelized cost of energy (LCOE) of an onshore wind project and can make otherwise promising projects uncompetitive in CfD auctions.

Solving this challenge requires a more holistic approach than the current “project by project” consideration. Given that the systems required to support radar improvements are now well understood, we believe it is time for the control of radar systems to support onshore wind farms to be managed centrally. The onus for making the radar wind farm compliant should be on those managing the radar systems. This could be supported by a reasonable contribution from industry, rather than being wholly financed by it as at present.

Maintain the CfD support scheme The CfD scheme is an example of policy action that has been very successful in dramatically reducing the capital costs of several renewable technologies. It is important that the CfD scheme continues, in order to deliver the scale of new renewable generation that is required in net zero scenarios.

To ensure that the power sector meets its targets for decarbonisation, capacity caps for future CfD allocation rounds must be reflective of amount of capacity for each technology that is required to deliver net zero, as set out in the renewable generation deployment scenarios produced by the Committee on Climate Change (CCC) and others. We recommend that the UK and Scottish Governments should work closely with the CCC and others to review scenarios for the capacity deployment of renewable technologies. The associated capacity caps in the CfD auctions should be set at levels that are consistent with these scenarios. This will ensure the right level of renewable capacity is deployed on a country wide level and provide confidence to investors and developers in the renewable industry nationwide that there is an enduring commitment to deliver net zero.

A Net Zero Duty for Regulators In addition to setting targets for actions to deliver net zero, EDF believes that the time has come to specify a net zero duty for all regulators, including:-

5  Ofgem,  all other members of the UK Regulators Network and  all bodies with environmental regulatory responsibilities, such as NatureScot.

It is, of course, quite possible to interpret current statutory duties as including support for climate change mitigation amongst other responsibilities. Ofgem, for example, recognises that climate change mitigation is important to protect the interests of future customers. However, at present there is no explicit, unambiguous direction to regulators to have special regard to climate change and the delivery of net zero.

The lack of an explicit net zero duty could mean that regulators have no clear basis to prioritise climate change mitigation over other factors. Indeed, they may often feel constrained that they cannot do so, because they have to have regard to their formal objectives; they may be concerned about the risk of legal challenge, such as judicial review, if they do not follow the letter of their legal obligations. This can lead to a lack of proportionality in decision making.

An explicit duty to support the achievement of the legally binding net zero target would not prevent them from quite rightly taking the full range of their obligations into account when considering an issue, but it would ensure that they are able to take a wider strategic view in reaching a decision.

It is this wider strategic view that is all too often lacking under current arrangements, particularly when being managed locally. This means that low carbon projects (including new renewable generation), which can make a major contribution to the transition to net zero, may be long delayed, or even frustrated altogether, because undue weight is given to relatively minor and localised potential detriments.

There are two ways in which such a change could be implemented and it may vary depending on the statutory framework under which various bodies are established:  It could be done through legislation that would impose a specific net zero duty on relevant bodies.  Alternatively, these bodies typically operate under guidance issued by the sponsoring department (e.g. BEIS in the case of Ofgem) and this departmental guidance could be updated to include a net zero duty.

In the past, in the energy sector, there have been concerns that a net zero duty could impose unduly onerous conditions on fossil fuelled generators. Whilst we acknowledge this concern, it seems likely that unabated fossil fuel use will be increasingly constrained by various measures regardless of the introduction of a net zero duty.

3. To what extent does the UK Government’s latest white paper – Powering our net-zero future – ensure that renewable energy targets will be met in the UK.

EDF welcomed the UK Government’s white paper “Powering our net-zero future”. This highlighted that “The UK has set a world–leading net zero target, the first major economy to do so, but simply setting the target is not enough – we need to achieve it” and went on to set out a clear vision of what is needed to reach net zero and the steps the UK must take to achieve it.

Following on from the white paper, EDF was pleased to see the UK Government’s recent announcement accepting the CCC recommendations for the sixth carbon budget, made ahead of COP26 later this year. We look forward to seeing the Net Zero strategy which will outline how the UK’s ambitious carbon budgets and net zero will be delivered. The specific capacity targets for offshore wind and hydrogen (of 40 GW and 5 GW by 2030 respectively), give industry clear short-term targets, which will enable development of UK supply chains and accompanying benefits. The offshore wind target also highlights

6 the scale of the challenge, given offshore wind capacity must triple, compared to current installed capacity.

However, supportive policies and incentives will also be needed. in addition to targets, to ensure that projects are financially viable and therefore deployable. For example, for the hydrogen target, the publication of BEIS’ Hydrogen Strategy, and information on preferred support schemes, will be crucial to ensure that this 5 GW aim can be met.

As has been widely recognised, by the CCC, National Grid, academics and industry, an increase in deployment of all renewable technologies will be necessary for the UK to meet its net zero targets. Given this, EDF was disappointed that there were only limited references to both onshore wind and solar technologies in the white paper.

The UK – and Scotland within it – has abundant natural resource suitable for the continued development of onshore wind and solar technologies. These technologies are the lowest cost renewables available and have substantial pipelines of projects that are ready to deploy. It is important that the net zero policy framework enables these technologies to reach their full potential in delivering interim, and net zero, targets.

Renewable energy sources

4. What variables have contributed toward wind energy providing more energy to the grid than any other renewable source?

Scotland has an abundance in natural resources suitable for the deployment of renewable technologies. This is evidenced by Scotland meeting 97.4% of its electricity demand through renewable energy in 20202 and the CCC’s recommendation that Scotland legislated a net zero target by 2045, due to its larger land area per person and significant carbon dioxide storage potential.

A key reason that wind energy provides more energy to the grid in Scotland than any other renewable source is that Scotland has some of the best wind resources in the world, with Scotland estimated to have 25% of all wind resource in Europe3. This enables high load factors for wind generators. Wind also provides energy all year round and its seasonal profile is well aligned to electricity demand, which is an additional advantage compared to some other types of renewable generation.

Given the high load factors achievable through wind generation in Scotland, this makes the costs of energy production relatively low, as there is a higher electricity output per unit capital cost of installation compared to other geographical locations. Alongside the high wind speeds, historic planning policy in Scotland has been supportive of onshore wind, which has also enabled many projects to be deployed without delay (although the planning regime has been more challenging in recent years, as we have explained elsewhere in this response).

The CfD scheme, and the ROC scheme before it, have been successful policy instruments to enable low cost investment in renewables and are much of the reason for the large increase in installed capacity of wind in Scotland over the last decade. The competitive nature of the CfD auctions has led to a reduction in technology costs for both onshore and offshore wind, which ultimately benefits the consumer. The fixed price and duration of the CfD contract has increased the pool of investors interested in renewable infrastructure projects in the UK, which led to reductions in cost of capital, and in turn wind is now one of the lowest cost options for the decarbonisation of power in the UK.

2 Energy Statistics for Scotland, Q4 2020 Figures, March 2021 3 ScotsRenewables, Scotland Has Over 25% Of Europe's Wind Resources (scotsrenewables.com)

7 To date, onshore wind has been deployed in Scotland at much larger scale than offshore wind, solar and hydro. Compared to offshore wind, onshore wind is a more mature technology and this has enabled a high level of deployment, combined with availability of suitable sites both on terms of space and wind regime. However, offshore wind is now approaching a similar level of maturity to onshore wind and this should enable more rapid growth in deployment in years to come.

Solar has recently become comparable in cost and maturity to onshore wind. However, in general Scottish sites are less attractive than more southern sites due to lower levels of insolation (the sunlight resource). Nonetheless, there are locations in Scotland with an attractive solar profile and further development is likely in future, particularly with the continuing enhancements in solar technology. Scotland does benefit from long hours of summertime daylight and, with the fall in cost of solar photovoltaic panels in recent years, the economic viability of such projects has improved. Therefore, Scotland has significant potential for the development of solar technologies and the Scottish Government should ensure this technology can be deployed at scale. A further benefit is that the generation profile of solar is not correlated with onshore or offshore wind, resulting in natural synergies which will help with wider system balancing.

There is a limited availability of suitable sites for new larger scale hydro sites, so its further deployment is likely to remain limited to a small number of specific opportunities.

5. Why does account for such a small proportion of the total energy output of renewables in Scotland?

Most marine energy technologies are still at an early stage of technology readiness and therefore in Scotland and the rest of the UK only a small number of demonstration scale projects have been developed. Most marine energy projects in the pipeline in Scotland continue to be of relatively small capacity. Capital costs for projects remain high, as these technologies have not yet moved from a demonstration stage to commercial readiness. Other technology types in Pot 2 of the CfD, such as Advanced Conversion Technologies and Anaerobic Digestion, have lower costs than wave and tidal technologies, and as a result these marine technologies have not been successful in the CfD auctions to date. It is possible that alternative methods of funding would be more appropriate for marine energy projects still at a pre-commercial stage.

6. What is being done to develop and research other forms of renewable energy in Scotland such as wave/tidal energy and carbon capture usage and storage (CCUS) energy or others?

Firstly, EDF would like to take the opportunity to clarify that carbon capture usage and storage (CCUS) is not a form of renewable energy if the input fuel is of fossil origin. Carbon capture usage and storage is best described a sequestration technique applied to an energy process (or other source of carbon emissions), rather than being an energy source in itself.

CCUS can be applied to many industrial processes and other sources of carbon emissions. As a result, CCUS will be an extremely important technology for the UK to reduce carbon emissions in those sectors where full decarbonisation is not possible, nor realistic. Those industrial sectors that do not have immediate low carbon alternatives readily available should be the priority for the application of CCUS, rather than the energy sector, which has already has a wide range of deployable, low cost, low carbon options.

Hydrogen has potential as an effective low carbon energy carrier, and therefore has an important role to play in the road to net zero. Scotland has ample opportunities to deploy electrolytic hydrogen production facilities, with high load factors from offshore and onshore wind making these forms of green hydrogen production more cost efficient than alternative renewable energy sources.

8 EDF welcomes the ambition of the Scottish Government’s recent hydrogen policy document and the £100m which has ben allocated to the development of hydrogen projects between 2021 and 2026. This vision sets a clear framework for industry and investors to respond with confidence. However, the success of hydrogen development in Scotland will also rely on the imminent UK Government’s Hydrogen Strategy and preferred business models. It is important the BEIS hydrogen business model proposals are published promptly, so that early low carbon hydrogen projects can be financially viable. This will ensure that projects can be deployed in the near future, which will contribute to the Scottish government’s ambition of 5 GW of operational low carbon hydrogen production by 2030.

Employment in renewable energy sector

7. What policy decisions do the UK and Scottish Governments need to make to increase the number of jobs in the renewable energy sector?

In order to ensure a steady flow of jobs in the renewable energy sector, a steady pipeline of projects is needed across all renewable technologies. The announcement of the continuation of Pot 1 technologies in CfD auctions in Auction Round 4 has been helpful in this respect, as it has given a clear signal of continuing support to the UK supply chains needed for both onshore wind and solar photovoltaic technologies. The CfD auction design will need to ensure that a substantial capacity of both technologies is successful in the upcoming auction, as this will secure the benefits of a diverse energy mix and in turn will lead to a more secure and resilient system.

EDF welcomes the UK Government’s recent budget announcement which confirmed the funding of offshore wind port infrastructure in Humberside and Teesside, along with Freeport status being awarded to both ports and six others in England. Investment in port infrastructure will be crucial to develop UK supply chain capabilities and ensure that the UK and Scotland are able to capitalise on export opportunities.

Scotland has adapted this policy as “Greenports”, creating a similar package of customs and tax relief, but with commitments to net-zero, fair work criteria and ensuring payment of the living wage. It is important that Scotland also capitalises on the investment interest in port infrastructure and attracts more manufacturing facilities. EDF Renewables is supportive of the Scottish Governments proposals for two Greenports, as this will ensure an equal distribution of supply chain benefits across the UK. The UK and Scottish Governments must collaborate on industrial planning and supply chain investment, as a more strategic approach is needed to ensure a fair distribution of the benefits, whilst ensuring workers’ rights and net zero commitments are not compromised.

8. How effective has the renewable energy sector been in producing careers for Scottish people?

The renewable energy sector has been very successful in producing careers for Scottish people, with Scotland being recognised globally for its innovation in offshore wind. As reported by OWIC, the total UK offshore wind workforce as at December 2020 employed 26,093 people, 30% of which are in Scotland.4 The report also projects that by 2026 UK offshore wind is forecast to employ 69,848; 40,700 of which are direct jobs and the remainder indirect, highlighting the contribution the renewable energy sector can make to a Green Recovery. The offshore wind sector has committed to increasing UK content to 60% by 2030, proving the wider commitment from industry to use local companies where possible. In turn, this will result in an increase in local development, manufacturing and installation jobs.

Investment in other types of renewable and low-carbon infrastructure will also result in job creation. In particular, for onshore wind, jobs will be created in electronic control systems, manufacturing and supplying turbines components and remote monitoring, to name a few. A Vivid Economics report

4 OWIC, Offshore Wind Skills Intelligence Model Report, February 2021

9 forecasts that ‘deploying 35 GW of onshore wind by 2035 could support 14,000 jobs’ and much of this is likely to be located in those local authorities most in need of high paying jobs.5

EDF Renewables has almost 500 MW of generation capacity currently in operation in Scotland over eight onshore wind farms, and 480 MW in construction. To support the development of these renewable projects EDF currently has 105 direct employees and 48 contractors attached to the Edinburgh office, as of 31st March 2021. To demonstrate some of the wider economic benefits, in addition to direct employment, EDF would like to present two case studies:

Case Study 1: 450 MW Neart Na Goithe (NnG) Offshore Wind Farm

 The NnG project currently has 80 jobs in the Edinburgh project office. In addition, there will be 50 new jobs in the future Operation & Maintenance base.  290 jobs will be created by Harland & Wolff to carry out the fabrication and load-out of eight of the foundation jackets, using its newly acquired Methil facilities in Fife for the fabrication work  The NnG project has spent £96 million to date on Scottish contracts; £44 million through direct contracts with more than a hundred businesses in the Scottish supply chain, and the remainder through Tier One contracts.  Where services cannot be sourced in Scotland, the wider UK supply chain will be utilised, totalling £175 million.  The Port of Dundee has already been named as the wind turbine hub for the construction phase of the NnG project.  The Port of Leith is being used extensively as the marine logistics base for the pile casings for the turbine foundations and Eyemouth Harbour has been named as the Operations & Maintenance Base for the 25 years life of the wind farm.

Case Study 2: 177 MW Dorenell Onshore Wind Farm

 £50 million was spent in the local economy during construction.  A new Ranger Service is in place onsite with two new members of the team, who are working to improve and maintain the environment around the wind farm for wildlife and visitors.  £1.4 million will be spent locally on operating costs in 2021, covering facilities management, constructing a shed to keep snow clearing machinery, the new visitor centre, an access management strategy, habitat management and kitting out the control room. All of this work is carried out locally.

As well as direct job creation, EDF Renewables has set up Education and Training funds at two of our onshore wind farms; Corriemoillie and Burnhead Moss. These funds focus on supporting local people pursue academic and professional qualifications and training opportunities, contributing to creating job opportunities in the local area. Both funds will make awards throughout the operating life of the wind farms, with Burnhead Moss recently receiving its 300th application. Each of our onshore wind farms have a dedicated community fund to spend on improvements in the local area during its development and over the lifetime of its operation. This demonstrates the further positive economic benefits that the development of renewable projects has on local communities, in addition to direct job creation.

9. What UK and Scottish Government support would facilitate the growth of jobs in this sector?

As stated in Question 7, a significant pipeline of projects is required in order for the local supply chain to develop and job opportunities to continue to grow. To ensure that the project pipeline continues to grow, clarity needs to be provided on upcoming CfD auctions and actions implemented to address current barriers to further deployment. The three most important enablers for continued onshore wind

5 Vivid Economics, Quantifying benefits of onshore wind to the UK, June 2019

10 development are planning, investment in grid and radar mitigation. Please refer to our response in Question 2 for more detail on the current issues and recommendations.

The ScotWind seabed leasing process is of crucial importance to ensure a continued growth and expansion of fixed foundation and floating offshore wind technologies in Scotland. This will help unlock significant investment in the supply chain and create more green jobs across the sector. Therefore, EDF Renewables welcomed the timely review of the process by the Crown Estate Scotland, as this will ensure that Scotland is on track to meet this target by 2030, which is when the Scottish Government’s climate change plan requires a zero carbon electricity system.

There is currently 5.7 GW of consented offshore capacity in Scotland and the Scottish Government has set a target of 11 GW of offshore wind capacity by 2030, leaving 5 GW to be procured on top of the already consented projects. Given the UK target of 40 GW by 2030, this target for Scottish capacity does not seem ambitious enough, given the extensive resource which has not yet been developed. Therefore, EDF would like to see the Scottish Government increase its target for the deployment of offshore wind by 2030, as this will send a strong message to developers and encourage the growth of the local supply chain to support the Scottish Government’s ambition.

In particular, it is important that Scotland takes advantage of opportunities to develop its floating offshore wind supply chain, as this could result in a significant first mover advantage, enabling Scotland to export services as an international floating offshore wind market develops. It is imperative that ScotWind is successful in procuring floating offshore wind sites, as well as fixed foundation sites, as this will lead to some of the first commercial scale floating wind projects in the world, therefore developing local supply chain and creating jobs to support the sector.

10. What do the UK and Scottish Governments need to do to achieve a ‘just transition’ for workers in the oil and gas industry to successfully redeploy to the renewable sector or other sectors?

We have no comments to make on this question.

11 Intergovernmental relations

11. How effective have the Scottish and UK Governments been in harnessing Scotland’s renewable energy potential?

The Scottish and UK Governments have to date been very successful in harnessing Scotland’s renewable energy potential, particularly in the deployment of onshore wind which accounts for over 70% of Scotland’s installed capacity. The pace of deployment has been fairly steady since 2009, and has only

recently started to slow, as is observable in the below plot.

Source: BEIS Energy Trends6

Therefore, the achievement to date should be celebrated, whilst recognising that it is crucial that momentum is maintained in order for Scotland to meet its interim and net zero targets. See our response to Question 2 for the key enablers and recommendations for what is needed to ensure a steady deployment of renewable technologies in Scotland.

12. How effective has consultation between the two Governments been on the development and design of renewable policies?

We have no comments to make on this question.

13. What discussions took place between the Scottish and UK Governments in preparing the Energy White Paper?

We have no comments to make on this question.

14. How will the Energy White Paper affect the renewable energy sector in Scotland?

6 BEIS Energy Trends, March 2021

12 Development of offshore wind will be needed in both Scottish and UK waters in order for the 40 GW offshore wind target by 2030 to be met. Heat and transport are priority sectors for the UK to decarbonise next and the Energy White Paper provides the supporting context needed to ensure Scotland’s abundant onshore and offshore wind resource is harnessed to address this. The UK Government must work closely with the Crown Estate, and the Crown Estate Scotland, to address seabed issues and environmental protection of the marine environment. This will ensure the UK can quickly deploy fixed foundation and floating offshore wind at scale.

Scotland has an abundance of the resources necessary for the production of low-cost, low-carbon hydrogen, and the Energy White Paper set out clear plans and aims to make the UK a world leader in the production and use of clean hydrogen. The aim for 5 GW of low-carbon hydrogen production capacity by 2030 and available funding of £240 million through the Net Zero Hydrogen Fund gives a strong message to industry that the UK Government is committed to kickstarting a hydrogen economy. This target will help to focus industry on developing low-carbon hydrogen in the near term, of which Scotland has a large part to play.

15. How can the UK and Scottish Governments work together effectively to achieve their respective targets of net zero by 2050/2045?

It is crucial that the UK and Scottish Governments work together to ensure net zero targets are met. In order for Scotland to meet its targets, action is needed across both devolved and reserved matters, and where these are in alignment it will act to drive growth and set clear ambitions for the whole of the UK.

Where areas are largely reserved, it is important that the UK Government works closely with Scottish Government, as UK-wide policy measures will have direct implications for both Scotland and the UK’s delivery of their net zero targets.

Hydrogen is one example of this, where many of the regulatory and legislative levers required for projects to be deployed are determined at a UK level. The Scottish Government’s Hydrogen Policy Statement recognises the need for a rapid pace in order to capitalise on opportunities within the global and domestic market. Success will, in part, be dependent upon the UK Government’s publication of its Hydrogen Strategy and recommended support schemes. Therefore, the Scottish Government should engage closely with the UK Government on the development of a UK policy and regulatory framework for hydrogen, to ensure that both Scotland and the UK are well positioned to move quickly to capitalise on this market.

May 2021

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