GY/NR

19 December 2011

Proposed Plan Representations SESplan

Claremont House

130 East Claremont Street EH7 4LB

Dear Sir/Madam

SESPLAN: PROPOSED PLAN – REPRESENTATION ON BEHALF OF SCOTTISHPOWER GENERATION LIMITED

ScottishPower Generation Limited (SPGL) is a significant landowner in the Strategic Development Plan Area and welcomes the opportunity for further engagement in the SESplan preparation process.

SPGL owns and operates existing -fired power stations at Cockenzie, and Longannet, . The continued role of Cockenzie and Longannet as generating stations is recognised in National Planning Framework (NPF) 2, through their inclusion as a priority a ‘national development’.

SPGL recently secured consent under S36 of the Electricity Act 1989 for the re- powering of Cockenzie , including the replacement of its existing coal- fired generating units with modern, high-efficiency Combined Cycle Gas Turbine (CCGT) units.

In addition, as part of a multi-disciplinary consortium, SPGL recently completed a twelve-month study which considered the introduction of commercial scale Carbon Capture and Storage technology at Longannet.

In the first instance this representation considers SESplan’s general approach to national developments and the implications of such status, before focussing specifically upon and then .

General References to National Developments The SESplan area includes a number of significant infrastructure developments identified within the National Planning Framework as priority national developments. The aims of the SDP, as outlined at paragraph 17, should reflect this. In this regard

SESplan representation on behalf of SPGL Page 2 19 December 2011

SPGL requests the inclusion of the following additional aim at paragraph 17: “Promotes and where possible facilitates the delivery of priority ‘national developments’ as defined by Scottish Government, as well as infrastructure associated with such developments.”

Similarly, SPGL requests the amendment of Policy 1B – The Spatial Strategy: Development Principles through the addition of the following new bullet point which recognises the role of Local Development Plans in promoting the delivery of priority national developments: “Recognise the need for priority national developments as defined by Scottish Government and acknowledge a general presumption in favour of major infrastructure projects consistent with national development designations. Furthermore, Local Development Plans will facilitate the efficient delivery of national developments and infrastructure associated with such developments, subject to the satisfaction of the relevant matters to be addressed through the development management process, as defined by the National Planning Framework.”

In addition, SESplan should include a definitive statement on the implications of national development status in accordance with the aforementioned amendments to Policy 1B and explicitly require Local Development Plans to promote and facilitate such developments through generic development policies and where possible, through appropriate site specific land use policies. A statement to that affect should be incorporated within figure 2 and at paragraph 28.

As referenced at figure 2, new non-nuclear baseload generating capacity at both Cockenzie and Longannet Power Stations is identified as a priority national development within the National Planning Framework. This national development status is acknowledged within Policy 10(a): Sustainable Technologies. SPGL endorses Policy 10(a) as currently drafted and welcomes the requirement on Local Development Plans to support the delivery of national developments and associated infrastructure.

Cockenzie Power Station In addition to the reference within Policy 10(a), in providing commentary on the ‘East Coast’ at paragraphs 48-59, SESplan should specifically reference Scottish Government’s recognition through the National Planning Framework of the continued role of Cockenzie Power Station as a large-scale generating plant. Accordingly, SPGL requests the addition of the following text after paragraph 52: “Existing locations within East Lothian contribute a significant proportion of ’s electricity supply. The East Lothian LDP will promote continued electricity generation from Cockenzie Power Station in accordance with its national development designation, including any associated infrastructure.”

Longannet Power Station Similarly, in commenting on the ‘Fife Forth’ at paragraphs 60-70 should make specific reference to the continued role of Longannet Power Station as a large-scale generating plant. In order to properly reflect its status as a priority national development, SPGL requests the addition of the following text after paragraph 68: “Longannet Power Station is Scotland’s largest electricity generating plant and is one of the largest power stations in the UK. Its ongoing role is recognised through its identification by Scottish Government as a priority national development and the

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SESplan representation on behalf of SPGL Page 3 19 December 2011

Fife LDP will promote continued electricity generation from Longannet Power Station (including any associated infrastructure) accordingly.”

We trust this representation will be taken into account in progressing SESplan and would be pleased to discuss its content in further detail. Should you have any queries, please contact Grant Young on 0131 469 6042.

Yours faithfully

GVA For and on behalf of SCOTTISHPOWER GENERATION LIMITED

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PROPOSED PLAN – PERIOD FOR REPRESENTATIONS

7 NOVEMBER 2011 – 19 DECEMBER 2011

Form P3 – Submission of Representations

The Proposed Plan has now been published. The six week period during which Representations may be submitted is open from Monday 7 November 2011 until 5pm on Monday 19 December 2011 . Representations received after this date will not be accepted .

Should you intend to submit a Representation, whether electronically or in writing you should do so using this form (Form P3). A separate Form P3 must be completed for each issue that you wish SESplan to consider . You may raise as many issues as you wish.

In line with Scottish Government advice, you are reminded that each issue must be no longer than 2,000 words whether submitted electronically or in writing. A summary of the issue that you wish SESplan to consider together with the modification / change to the Proposed Plan that is sought (to a maximum of 400 words in length) must also be provided.

There is no automatic opportunity for parties to expand on their Representations later in the process.

All Representations should be submitted wherever possible electronically to, [email protected]

Representations may also be submitted in writing to,

Proposed Plan Representations SESplan Claremont House 130 East Claremont Street Edinburgh EH7 4LB

Queries should be directed to a member of the SESplan administration team on 0131 524 5164.

FORM P3 – SUBMISSION OF REPRESENTATIONS FOR SESPLAN USE ONLY Reference No. PP / / Contact Name Organisation GVA On Behalf Of (if Applicable) ScottishPower Generation Limited Address Telephone Email Electronic Only x By what means are you Hard Copy Only submitting this Issue? Both

(Please tick as appropriate) Further Information Attached? Yes x No Attached correspondence from GVA dated 19 December 2011 Does this Representation relate Yes No x to a previous MIR submission? If Yes, Main Issues Report Ref No. City of Edinburgh East Lothian Part of SESplan to which this Fife Issue relates? Midlothian

(Please tick as appropriate) Scottish Borders West Lothian General x Page Number 6 Para Number 17 Foreword

Section Introduction SESplan, The Capital City Region – The Vision x (Please tick The Spatial Strategy only one entry) Framework for Delivery Glossary The Vision SESplan – Profile of the City Region SESplan – The Aims of the SDP x Regional Core East Coast Fife Forth Part of the Proposed Plan to which this Issue relates? Midlothian / Borders West Lothian Employment Land Sub Section Town Centres and Retail

(Please tick Minerals only one entry) Housing Land Requirement Providing Flexibility Affordable Housing Transportation Other Infrastructure Energy Green Network Green Belts Waste Water and Flooding

1

Detail of Issue (See the attached Guide to Completion)

SESplan aims do not sufficiently recognise the importance of national developments as defined by Scottish Government.

Additional ‘aim’ to be included to reference priority national developments, as defined by the National Planning Framework – please refer to attached correspondence

2

Summary of Issue (See the attached Guide to Completion)

Additional ‘aim’ to be included to reference priority national developments, as defined by the National Planning Framework – please refer to attached correspondence

Details of Modification / Change sought to the Proposed Plan (See the attached Guide to Completion)

Addition of new aim – “Promotes and where possible facilitates the delivery of priority ‘national developments’ as defined by Scottish Government, as well as infrastructure associated with such developments.”

3

Summary of Modification / Change sought to the Proposed Plan (See the attached Guide to Completion)

Addition of new aim – “Promotes and where possible facilitates the delivery of priority ‘national developments’ as defined by Scottish Government, as well as infrastructure associated with such developments.”

4

FOR SESPLAN USE ONLY Issue Reference No. PP / / Date Received Yes If Electronic Submission saved No onto X Drive? Date Initial Yes If Electronic Submission only, No Hard Copy Printed? Date Initial Yes If Hard Copy Submission placed No into Hard Copy files? Date Initial Yes If Hard Copy Submission only, No Submission Scanned? Date Initial Yes No Redacted Date Initial Yes Acknowledgement Created and No Sent? Date Initial Yes Administration Entered on No Database Date Initial Yes SESplan Response Entered on No Database Date Initial

SIGN OFF

Name Administration Signature Date Name SESplan Signature Date

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