Written evidence submitted by EDF Renewables (RES0009) Scottish Affairs Committee Response from EDF Renewables to the Call for Evidence on Renewable Energy in Scotland 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 energy storage. 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 wind power, 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 wind farm 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 Paris 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 electricity generation 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 Europe. 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.