Aviation Investment Fund Company Limited C/- RenewableUK Association Limited 4th Floor Greencoat House Francis Street London SW1P 1DH 29 May 2017 Scottish Government Onshore Wind Policy Statement (January 2017 consultation) – AIFCL response Aviation Investment Fund Company Limited (AIFCL) welcomes the opportunity to respond to the Scottish Government’s Onshore Wind Policy Statement consultation, in particular with respect to questions 5.1 (strategic approach to radar mitigation) and 5.2 (increase in the Eskdalemuir Seismic Array exclusion zone). We set out our responses below. Background AIFCL was incorporated in early 2009 as the wind industry funding body to support the various work streams under HMG’s Aviation Plan, overseen by the then-DECC chaired Aviation Management Board. AIFCL is made up of 19 wind energy developers, ranging from utilities to smaller independent developers. AIFCL’s active members comprise ScottishPower Renewables, Innogy, SSE Renewables, E.ON, Vattenfall, RES, Banks Renewables, EDF, Falck Renewables, Ecotricity, Airvolution, Engie, Infinis, EnergieKontor and REG Windpower. AIFCL has raised over £5m to fund R&D activities under the Aviation Plan. The objective of this R&D has been to identify and support bringing to market technologies which would, in the short run, mitigate the impacts of wind turbines on legacy radar surveillance infrastructure and, in the longer run, ensure that wind farm tolerance is an integral element in next generation surveillance equipment. AIFCL also funded, with the Scottish Government and Ministry of Defence, the study by Xi Engineering for the Eskdalemuir Working Group (published in 2014), which resulted in the comprehensive revision of the Eskdalemuir seismic budget allocation methodology. To date, in aggregate, AIFCL has spent over £4m on these R&D and related projects – see the attached confidential annex for further details. Question 5.1 Do you agree with the Scottish Government proposal to facilitate a strategic approach to the access to, and the cost of using, data from civil radar to mitigate the impacts of wind development on civil aviation operations? AIFCL agrees that the Scottish Government should facilitate a strategic approach to cost-effective civil radar feed mitigation access. However, AIFCL considers that this question relates to only one element of the wider civil and military aviation safeguarding issue, namely the cost and time to deploy short term, interim mitigation for legacy equipment until such time as the responsibility for Registered Office: c/- RenewableUK Association Limited Page 1 4th Floor Greencoat House, Francis Street, London, SW1P 1DH UK Registered in England No. 06808528 VAT Number 991 5716 82 Aviation Investment Fund Company Limited procuring wind farm tolerant surveillance systems is assumed by aviation stakeholders, both civil and military. Wind turbines are now an established and fundamental part of the UK energy system and should no longer be viewed as a disruptive entrant. The Scottish Government needs to consider when aviation stakeholders will be required to accept that wind turbines (of any scale) form part of the operational baseline against which they need to specify aviation communications, navigation and surveillance (CNS) infrastructure (in much the same way as aviation stakeholders currently include in their operational baseline tall buildings, grid pylons, broadcast transmission infrastructure, road traffic, shipping, etc). AIFCL believes that wind power should now be considered as part of the environmental and operational baseline which aviation needs to accommodate going forward. When aviation stakeholders renew or upgrade their radar surveillance infrastructure henceforth (and by 2030 at the latest), they should assume the responsibility and cost for ensuring that their surveillance systems can accommodate wind turbines and are thus fit for purpose in the evolving environment. This is no different to how aviation has had to address to many other factors including, for example, environmental responsibilities such as CO2 emissions. Aviation stakeholders should no longer look to the wind industry to fund their business essential surveillance infrastructure upgrades in light of this new baseline, particularly given the now accepted availability of wind farm tolerant radars (as are being deployed at the Scottish Central Belt airports). The impact of wind turbines on aviation surveillance assets was first comprehensively discussed in the DTI’s 2002 Wind Energy and Aviation: Interim Guidelines (doc ref ETSU W/14/00626/REP). As noted above, AIFCL has significantly supported R&D and related activities to date with the view to removing aviation as a barrier to deployment of wind turbines. Some of this investment has led to the deployment of new wind farm tolerant capabilities (e.g. the Raytheon upgrades to Lowther Hill and Great Dun Fell radars). Given that the average capital cycle of aviation surveillance infrastructure is generally 15-20 years and the technological developments and the evolving airspace and surveillance environment under the Single European Sky, AIFCL argues that now is the appropriate time to commence the transition of responsibility to aviation stakeholders for ensuring wind farm tolerance in surveillance infrastructure. AIFCL recognises that this transition period may need to be somewhat extended but by 2030 by the very latest, aviation stakeholders should fully assume this responsibility and no longer look to support from the wind industry for ensuring their surveillance systems can accommodate wind turbine effects. In the interim, AIFCL agrees with the Policy Statement that efforts should be put in place to facilitate a strategic approach to cost-effective civil radar feed mitigation access, particularly in light of the closure of the RO and the absence of any apparent route to market making the cost reduction imperative even more pressing. Aviation stakeholders also need to appreciate that wind power is undergoing a technological generational shift, with the deployment of next generation (taller, larger rotor diameter, higher MW rated) turbines generally available in the global market, rather than bespoke UK turbines that are technically restricted. This shift is an essential component of reducing the cost of energy to the Page 2 Aviation Investment Fund Company Limited consumer. Consequently, it is not reasonable for aviation stakeholders to expect “like for like” repowering and new build. To this end, AIFCL requests the Scottish Government to take the lead in working with stakeholders, notably the CAA, the MoD and Department for Transport, to align policies and strategies to reflect this evolution in surveillance technology and the environmental baseline (i.e. inclusive of wind turbines). In addition, planning regulations and guidance and aviation safeguarding processes will need to evolve to reflect this change of responsibility for the procurement of fit for purpose wind farm tolerant radar infrastructure. 5.2 Do you agree with the Scottish Government proposal that the exclusion zone round the Eskdalemuir array should be set at 15 km? AIFCL agrees with the Scottish Government’s proposal that the exclusion zone around the Eskdalemuir array should be set at 15km. As noted above, AIFCL supported and together with the Scottish Government and MoD financially contributed to the work of the Reconvened Eskdalemuir Working Group which culminated in the publication of Xi Engineering’s report, Seismic vibration produced by wind turbines in the Eskdalemuir region: Release 2.0 of Substantive Research Project (2014). The 2014 Xi Report comprehensively reset the budget governing the array’s safeguarding and released significant MW for deployment. As development continues, the budget is progressively depleted – the closer turbines are to the array, the more budget they consume; hence the recommendation to extend the exclusion zone. As at 22 September 2016, according to MoD figures, 78.2% of the noise budget had been allocated (up from 57.7% on 31 December 2013). It is important to note that once the current budget is exhausted, there will be very little opportunity for further wind turbine development within the 50km safeguarding zone without the removal of existing turbines. As part of the Eskdalemuir Working Group output, AIFCL contributed to the development of a safeguarding tool for ongoing budget management by the MoD. AIFCL suggests that, to increase transparency of the allocated and remaining budget, the Scottish Government and MoD should consider establishing a public-facing list and map of developments in the area that are in planning and/or operational, based on this safeguarding tool’s output. Page 3 .