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Southern Uplands Alliance representation to The Royal Society of Issues for ’s Energy Supply – Independent Inquiry 2005/2006

15 July 2005 About the Southern Uplands Alliance (SUA) The Southern Uplands Alliance’s focus is on the issues surrounding wind energy. Groups from all areas of the Southern Uplands have joined forces, united in their concern about the proliferation of wind turbines throughout the region. The implications for our natural heritage, landscape and wildlife habitats and of course for our tourist industry are serious.

Representing groups from coast to coast, from to , SUA aims to raise public awareness of the scale of the issue across the region, to share ideas and information about wind power developments and to act as a support network. SUA monitors the number of turbines both operational and in the pipeline in the region. This has already reached a massive total. A chain of around 1400 wind turbines – and counting - will stretch from the West to the East coast of the South of Scotland, whilst installed capacity totals 1683MW.

SUA member groups include:

Abingdon, Crawford & Elvanfoot - South Broadmeadows Action Group – Selkirk, Doon Valley Windfarm Action Group - Ayrshire Friends of Stallashaw Moss - Galloway Landscape and Renewable Energy – & Galloway Lammermuir Protection Group – Scottish Borders and Save our Borders Scenery – Dumfries & Galloway, Scottish Borders Toddleburn/Hartside Action Group - Scottish Borders Trees Not Turbines/Forest of Ae - Dumfries & Galloway Walkerburn Action Group – Scottish Borders Wiston and Roberton Against Wind Factories - Lanarkshire

The problem with wind The accelerated growth of the wind power industry, on the back of substantial subsidy via the Renewables Obligations Scheme, has occasioned a growing realization that the ad hoc consenting of wind power developments in some of the country’s most significant areas of natural resource is a naïve approach to meeting the electricity requirements of the nation. The details of the arguments against the economics, politics and technology of wind are well documented elsewhere and this representation does not aim to examine them in great detail. Rather it summarises the concerns that have influenced opinion in the region and resulted in the formation of SUA.

Renewable energy targets There are already enough consents to meet Scotland’s renewable energy targets. OFGEM predict a peak demand of 6517MW for the whole of Scotland in 2010. 18% of this is 1173MW. As we have seen, the installed capacity consented or in the pipeline in the Southern Uplands already totals 1683MW already consented or in the pipeline. On top of this, the Highlands alone can already meet 96% of the target, having 1125MW of approved or operational renewable plants.

Net greenhouse gas and other pollution savings – and cost It is important that monitoring mechanisms are in place to validate such statements. It appears that this is not the case, as the Scottish Executive has been unable to produce figures to demonstrate what, if any, and where CO2 emission cuts have been made as a result of the existing or planned wind power stations in the country. It should also be noted that figures published earlier this year reflect that UK CO2 emissions rose by 1.5% in 2004, an increase for the second year running.

It is essential that a mechanism be established to measure and record detailed and validated figures are available in respect of the actual CO2 emissions saved by the operational wind sites in Scotland.

Power from wind installations in the Southern Uplands will displace units from low-emission Closed Cycle Gas Turbine stations, rather than from coal-fired stations. They will not completely close down any CCGT stations. There will be 60% spinning reserve from Open Cycle Gas Turbine stations, which generate 30% more emissions than CCGT.

So developers’ claims for emissions reductions are based on unsubstantiated assumptions and are wildly optimistic. Ditto claims for load factors of 30-35%. World leaders Germany and Denmark reach around 20%. Moreover, wind power can provide no firm capacity. And if, as predicted, global warming brings increased gale force winds, then it is extraordinary that the technology marketed as helping to solve the climate change issue is unable to cope with the very conditions that it brings. We know from experience at Crystal Rig in the Southern Uplands exactly what happens to wind turbines that do not automatically shut down in gale force conditions.

Wind energy costs around three times as much as other energy sources and increased energy costs are resulting in job losses. Transmission and back-up power costs amount to a further 14 – 21%.

This is a question of particular significance as these statements purport to underpin the core justification for constructing this type of industrial installation in significant landscape areas.

Social impact The practice of offering incentives in the shape of “community funds” has split communities across Scotland. SUA is happy to share experiences informally but for reasons of confidentiality will not detail them in this document. It is difficult to see how there is any place for this kind of activity in a planning process that claims to be objective and impartial. SUA calls for an urgent review of this policy.

Ecology The environmental impact is much more substantial than generally presented in Environmental Statements supporting planning applications. Extensive quarrying and permanent damage is caused by hundreds of tons of reinforced concrete in the base of each generator and by a major road built to each generator. All of this is permanent, enduring beyond the 25-year period often selected as the default decommissioning option in Environmental Statements.

The Macaulay Land Use Research Institute’s submission to the Scottish Parliament’s enquiry into climate change pointed out that it is not only Scotland’s forests that are important in sequestering carbon. It notes that: • the total carbon stored in Scotland’s soils is estimated at over 100 times the carbon in vegetation. Protecting this carbon store is crucial. • the deep peat blanketing the Southern Uplands has up to 10 times the organic content of agricultural soils in the eastern lowlands. • climate change is predicted to result in wetter, stormier weather patterns, so it is important to ensure that land use does not lead to increasing soil erosion and carbon flux.

In view of the EC’s action against the Republic of government due to the peatslide at Derrybrien, this is an issue that merits more serious consideration at a national level than has previously been the case.

Impact on tourism and the local economy In February 2005, the Scottish Borders Tourist Board (as it was then called), which represents an industry worth £200 million directly supporting over 3,000 jobs, expressed its concern that the Borders could become synonymous with wind farms if they were allowed on exposed open ridges in areas of great natural beauty. “The overall feeling of the board was that the landscape of the Borders is crucial to one of the most important industries in the area.”

Tourism is important to the economy of the Southern Uplands as a whole, including people from all sectors of society. The VisitScotland “Investigation into the potential impact of windfarms on tourism in Scotland” of 30 August 2002 reported that a significant proportion of tourists would not return to an area with a wind power station.

Visual impact and cumulative effect The impact of upwards of 1400 wind turbines – current generation over 400 feet high – will be to change the character of the Southern Uplands landscape. No cumulative impact assessment has been done on a regional basis and this is now a pressing issue, particularly given the significance of the Southern Uplands Way as a national resource.

Access requirements for the transportation of turbine components and construction materials to sites typically result in significant changes to country roads, rights of way and local and regional footpaths, changing the character of such routes in the Southern Uplands landscape.

Cultural heritage Scottish culture and spirit are developed and sustained by a number of factors, including our history, religion, education, legal system and our natural environment. These are the elements of our lives that foster our national pride. For the first time in our history, these heritage landscapes and wild places are now at significant risk. The spiritual essence of our landscape has been and will continue to be critical to the creative talent of Scotland through its literature, art and music. These factors are fundamental to all our lives and to put them at risk by encouraging the permanent disfigurement of our environment in the interest of profit to the few is not acceptable. Future generations will be seriously impoverished unless we stop to evaluate and consider the consequences of our actions.

In conclusion … For all these reasons, the Southern Upland Alliance requests the inquiry team to consider recommending a moratorium on the unrestrained and ad hoc development of wind power stations in Scotland until a cohesive and inclusive long-term national energy policy can be defined.

Sources Oxford Energy Comment, February, May 2005 - Oxford Institute for Energy Studies “Costs of Generating Electricity,” Royal Academy of Engineering 2004

Oxford Economic Research Associates Comment April 2005

“Quantifying the System Costs of Additional Renewables” – ILEX/UMIST report for the DTI, October 2002

“Tilting at Windmills – the Economics of Windpower” Prof David Simpson for the David Hume Institute