Enterprise and Culture Committee, 23 Mar 2004

Meeting date: Tuesday, March 23, 2004

Official Report 318KB pdf

---

Renewable Energy Inquiry

We recommence the meeting with agenda item 2, which is our inquiry into renewable energy in Scotland. I welcome Rob Gibson, who is attending for this item.

Our first panel consists of four witnesses: Andy Knill, who is the manager of surveillance and spectrum management from the Civil Aviation Authority's directorate of airspace policy; Allan Baillie, who is director of estate management for the Defence Estates agency of the Ministry of Defence; Air Commodore Simon Bryant, who is air officer Scotland and Northern Ireland; and, last but not least, David Hilton, who is the general manager of operational policy and investment for National Air Traffic Services Ltd.

Perhaps the witnesses could start off by briefly outlining what each of them does, which is perhaps not as clear in some cases as it is in others.

Good afternoon. I am responsible for surveillance and spectrum management policy within the directorate of airspace policy of the Civil Aviation Authority. We are responsible for the planning and use of all UK airspace structure to satisfy the needs of all aviation users. Within that, we have the policy lead for the Civil Aviation Authority for co-ordinating the impact of wind energy developments in the UK.

I am a director with Defence Estates, which is an agency within the Ministry of Defence that is charged with providing property solutions to defence needs. We are involved in energy efficiency, town and country planning and many other building and property aspects. Today, I will lead on the town and country planning aspects.

Convener, let me correct one thing. As air officer Scotland, I concentrate entirely on your country, as Northern Ireland has dropped off the perspective.

I represent the Ministry of Defence as a practitioner on a day-to-day basis. My two roles are to act as a higher-level representative of the Royal Air Force in Scotland and to have responsibilities for Royal Air Force Leuchars in Fife.

Operational policy and investment has a wide remit, but we basically cover everything from providing an interface with other air traffic service providers, such as European agencies, right down to things such as the environmental impacts on air traffic provision in the UK. My department is also responsible for all investment in new systems within National Air Traffic Services, from radars down to air traffic control centres and so on.

I start off by quoting paragraph 2 of the Ministry of Defence memorandum, which states:

"There is a perception among the stakeholders that MOD are a major stumbling block to wind farm development."

The previous page of the memorandum quotes from the energy white paper, which states:

"MoD has objected to a third of all recent on and offshore wind energy proposals."

Does not the second statement confirm the first, showing that the MOD is a major stumbling-block to wind farm development?

That could be said to be true statistically, but it depends on which statistics are chosen.

I chose the statistics that were given in your paper. Will you explain them?

Indeed. We see most applications at the pre-planning stage, where the statistics show that we tell a high number of developers that we regret that we are unable to go along with their proposal as it stands. However, the statistics for last year show that there were only three occasions on which we objected formally to a planning application.

I will narrate from my experience in Dumfries and Galloway. I was told a couple of years ago by the representative of a power company that it had given up trying to apply for wind farms in that area and was sending away any farmer who came to it, because no proposal was worth even considering. The effect of the MOD objections is to kill off any proposals before they get to the planning stage. The MOD does not have to object at the planning stage because people know before then that they will be stopped at that stage.

You may interpret the situation in that way if you so wish, but we wish to work on an individual basis with developers who wish to put up wind farms. We want to work with them in a way that allows them to achieve their aim.

I bring us to the example of Dumfries and Galloway, which is one of the tactical training areas. What progress have you made in that area in assisting to bring projects to fruition?

Are you looking for particular statistics?

I am conscious that, although there is a drive for renewable energy and we are in a fairly windy part of Scotland, Dumfries and Galloway is not covered with wind farms—nor would I wish it to be—but we seem to be going to the opposite extreme, where there are hardly any.

For those people who wish to develop a wind farm in that area, we have fairly good mechanisms in place by which they can approach us and I hope that we can work with them to get their plans through to approval.

I do not have any statistics for that particular area with me today because I did not come prepared to talk about individual cases. However, I can tell you the statistics for the overall number of applications that we have received since 1999: there have been 818 proposals in Scotland. In 2003, there were 353 proposals. Our rate of approval to date has been about 45 per cent. That is not as good as we would like it to be.

It seems that one of the primary reasons for MOD objections is the need to maintain low flying. In many of the communities that I represent, given the choice between wind farms and low flying, the people would choose low flying any day, but that is by the by. How relevant is low flying as a training method in the medium to long term? As warfare becomes ever more sophisticated, is it not true that the purposes of low flying are defeated by technology?

That depends entirely on the assumptions that one makes, with whom one is heading off to war and against whom one will fight. It might be a war or a conflict-prevention scenario. The reason for flying and training at low level is that it is one means of taking the conflict to the opposition, whoever that might be.

The most recent conflict in the gulf is an example of a heavily American scenario in which flying at medium level was a practical way of conducting much of the business, although not all of it. One operated under a large American electronic warfare umbrella against that particular opposition. An alternative assumption would be to participate in a European operation in which the same coverage would not exist. A higher priority would be placed on the requirement for low flying.

There are a number of other scenarios whereby one would not be looking at a full-scale fight; it would be more of an infiltration, whether to take photographs, to prevent conflict or to provide assistance after conflict. In such situations, the only way of getting into an area might be through low flying, dictated either by the circumstances or by the weather.

The Ministry of Defence prides itself on conducting operations well. One depends on flexibility; one is always trying to unhinge the opposition and maintain the advantage. Self-shackling is not a helpful way to begin one's preparation.

Can we draw from what you have said that the requirement for training in low flying is likely to continue at the current level for the foreseeable future, or is it likely to diminish?

The requirement to train at low level will remain. My judgment on whether it will diminish depends on the shape of the Royal Air Force in future. A white paper that is being considered at Westminster will undoubtedly lead to changes in the size and shape of the Royal Air Force, and indeed the size and shape of all the services. I have no information about what will happen. If the numbers went down, my assumption is that there would be less low flying.

I will turn the convener's question on its head. In the concluding paragraphs of your submissions, you say that you are committed to finding solutions and supporting the Executive to achieve its targets. I note that the Ministry of Defence's submission talks about the work that it is doing with QinetiQ and NOI Scotland Ltd of Kirkcaldy to develop blades that will not interfere with systems. Will the witnesses talk a bit more about what they are doing, how far their work has got, and whether it will conclude satisfactorily to allow the Executive to achieve its objectives? If that work will not conclude satisfactorily, why would that be and what impact would that have?

On the civil aviation side, we have delegated a lot of responsibility for safeguarding to individual airports and air traffic service providers—it is for them to make expert assessments of the impact of a development. The future role of the Civil Aviation Authority is to try to meet the Government's requirements in terms of transport policy while creating a process in which wind energy development can take place. To that end, we envisage that the CAA's role will be to develop better guidelines to help the aviation industry in its assessment of the impact.

In addition, we want to continue to work closely with the Department of Trade and Industry on the research and development of possible mitigation factors. Some of those will take a considerable length of time and will have considerable cost. The problem that the aviation sector has is that we cannot approve things until they have been demonstrated to work. Some of the technology solutions that have been proposed so far are too immature for the CAA to be able to approve or to say that they will act as a mitigation on, for example, radar.

We need to consider future aviation policy to see how developments in aviation might allow us to provide more realistic mitigations for the service providers to handle interference and other effects of wind farm development. We sit in the middle, and we see ourselves in a broker role. At the same time, our safety regulation group has to be able to give safety approval to services, taking into account the effects of wind farms.

As I said earlier, the Ministry of Defence treats each case on an individual basis and we work with developers to try to find solutions. Because of the numbers, we have put in more resources to try to reduce the time taken. We have been holding workshops and seminars with developers and environmental consultants so that they understand our issues and can take them on board at a far earlier stage. We are considering what additional mapping we could do, and that may well inform the process. In addition, we work closely with the British Wind Energy Association and the DTI. We seek to work closely with the Scottish Executive by means of a concordat to regulate how we work closely together. A team has gone around to meet the regional authorities; we are keen to get involved when they build their strategies so that we can let them understand our concerns and smooth the path as much as we can.

As you mentioned, we have also been involved in research, as opposed to funding it. QinetiQ, which you will appreciate is now an entity in its own right away from the Ministry of Defence, is using its expertise, but the Defence Diversification Agency, which is part of the MOD, is also involved in examining some of the technologies.

From our perspective, we are examining the processes rather than the technologies. The means of reducing the limitations that are imposed have already undergone a fair amount of consideration. Only the tactical training areas for low flying give us cause for concern. Purely from a flying perspective, the vast majority of areas in the UK low-flying system, in which people do not fly at less than 250ft, have already been taken out of that equation. That has already opened up wide opportunities.

NATS is approaching the issue with the power generators on four fronts.

Especially for some large applications in the Glasgow and Edinburgh areas, we are considering a new tracking system that has been developed by an air traffic management systems provider. As Andy Knill said, that system is still unfortunately very much at an R and D stage, so there would be an element of risk in our withdrawing objections at this time based on an unproven product. It is not as if we can buy such systems off the shelf. However, we have agreed that we will implement the system in an operational trial in parallel with our existing systems. Our primary concern is obviously safety, but what causes a problem for the power generators is the time that such trials take before we can allow their developments to go ahead and before we have sufficient knowledge about whether the new product will work to allow us to withdraw our objections.

One systems area that we are considering is potentially building a new radar site in the Scottish lowlands to fill in areas that, due to proposed wind farm developments, would be blanked off on existing radars. The proposal is still at an early stage, but we have some concerns about whether it is feasible, in that the new radar site could reduce our coverage at lower levels in some areas. Another systems area under consideration, for which we have done extensive flight trials for three or four applications in the Glasgow and Edinburgh areas, is the possibility of using existing filtering techniques to model how many turbines we could eradicate from our radar displays without losing any of the radar's performance in terms of aircraft detection.

We have also just started to revisit applications from power generators to consider allowing proposals to go through on a phased basis. The power generator would be asked to build first only those turbines that would not be in the line of sight and so would not be seen by the radar. In some cases, we would also discuss whether the height of turbines could be reduced to achieve the same purpose of being removed from the line of sight. Unfortunately, that also reduces the viability of many of the power generators' projects because it reduces the amount of power that would be generated. However, we are working on that.

Finally, as Andy Knill mentioned, we and the CAA are considering future developments in the air traffic world, such as the mandatory carriage of transponders in aircraft. That is some years away yet, but we fully support the CAA on that ideal, as it would reduce the need for primary radars—potentially in the areas where there are most problems with wind farms. We are also considering jointly with the CAA the possibility of changing the rules for certain types of airspace. That would reduce our need to make aircraft aware of the potential returns from wind farms that would be displayed on our radar.

I have been unable to think of a way of asking this question that will not provoke a predictable answer. Are you doing all that you can, as quickly as you can, to help the Executive achieve its objectives, as you state in your written evidence?

That is always a difficult question to answer, because people will always say that more could be done. We need to recognise that all of us are driven by resource availability and by priorities. We are all driven by impacts on our sectors, whether in defence, in commercial air traffic or as an independent regulator. Our primary need is to serve aviation requirements.

It is apposite that we become as involved as possible and—yes—we could probably do more with more resources. However, we have to make do with what we have as efficiently as we can—and do so with the best will to try to resolve the problems.

There has been a fantastic increase in development applications over the past four years. If I recall correctly, the numbers of applications three or four years ago were in the low hundreds per year; the numbers are now almost 1,000 a year. We have to consider those applications and we have to fund our work on them from our own resource pools.

Another difficulty is that, when a developer in the wind-energy industry has made an application for a particular area—an application that may have been objected to—they are not necessarily able to share information with other users. Round an airport, several different applications may come in from several different developers. All those applications may result in objections because they relate to the same problem. That causes our resource problem to get bigger. We could do more, but resources are an issue.

Do any of the other witnesses disagree with that?

Not at all. Statistics show that multiple applications are going through. I point out that more than 2,000MW of power would be online if the number of wind farms for which we did not raise objections in 2003 were built.

Andy Knill pointed out that resources are not unlimited. I add that, in the air traffic business, expertise can be a resource problem, in that one cannot just go out and buy more expertise off the street. It takes several years for a radar engineer to gain the necessary experience and knowledge to work on and analyse the systems.

From a practitioner's perspective, I would say that we have taken a long time to establish our tactical training areas. There is still a job to be done and those areas are the only way to go. Such training cannot be carried out to good effect in a simulator. We have used tactical training areas because of our consideration for the community. We will suffer if there is a reduction in such training areas.

My first question relates to the exclusion zone: in the NATS paper, it is 30km; in the MOD paper, it is 74km. I ask both organisations why there should be that difference.

The 30km in the NATS paper relates directly to current planning requirements. Proposals for areas within 30km of an airport have to be submitted to airport operators. In NATS, we do not think that that is adequate in some circumstances. For airports, we would like the figure to be increased: the distance should be about 45km. Our business also has on-route radars and we would like exclusion zones to be extended to cover any on-route radar site, because the same parameters apply.

Would Air Commodore Bryant comment on the MOD's position?

I will answer. There are two different types of radar: one deals with the safety of aircraft in the corridors that lead to airfields and the other deals with air defence. The latter is more about lower-level surveillance. The view of RAF experts, which I have to respect, is that in the current environment such defence requires a 74km clear distance.

If it is the view of RAF experts that is important, why did you jump in and take that question rather than let Air Commodore Bryant answer it?

I did so because I deal with that particular area with my minister, consulting the RAF and other experts.

May I ask both the MOD witnesses, or Mr Hilton, to comment on why those distances—notwithstanding the difference between them—are very different from the distances in Germany? I understand that in Germany wind farms are permitted within 10km of airports. Why should the situation be so different in another NATO country?

There are a number of reasons for that; it is not difficult to explain, in that each case has to be considered on its merits. Different airports operate in different ways and they have different approach aids. The environmental factors around airports are different: for example, an airport may be in the vicinity of another airport, which can have an impact on how far the approach extends and so on. A simple example is Glasgow airport, where I will be general manager until I take up my new post. On our easterly runway approach, when there are more than three aircraft in stream we join aircraft about 25 miles out. You can appreciate that the point at which they turn on to final approach is well outside 30km. If there happened to be a wind farm at about 30km, the alternative to turning the third aircraft on to final approach would be to keep it on hold, thus delaying its approach and extending its time in the air. We cannot consider airports—or countries for that matter—as a whole. We must consider each wind farm application in terms of its potential impact on its environment.

I know a little about the practical aspects of air defence. The object of low-level air defence coverage is to fill in any gaps that there might be, whereby we would not have sight for security purposes of the airspace within the UK air-defence reach. The trials that were done on that were run by the director of engineering and interoperability—that is where the figure of 74km comes from. The trials were done by the Royal Signals and Radar Establishment back in February 1995. The net results are that we have some 12 air defence sites around the UK that try to fill all the gaps in coverage to ensure that there is no incursion, and that we can bring to bear the rest of the air-defence network on anybody who intrudes in UK airspace and about whose intentions we are uncertain. The 74km figure feeds in to that pattern, which is a different process from looking at aircraft in an air-traffic control zone.

I can understand that, but I am rather surprised that NATO countries would have such significantly different limits. Although I understand that there can be no standard on this, and that the UK certainly has many facets that make it different from mainland Europe, it seems to me that the operation of wind farms in terms of interfering with radar must have the same effect wherever they are. I am not an expert on radar but, assuming that the pylons are the same height, can the effect on radar vary? I understand that buses, cars and other traffic—even flying kites—can show up on radar. How do you deal with that? My understanding also is that anything on a radar screen shows up as an X. That is a rather unsophisticated analysis—perhaps you could give me some greater detail on that.

As I said in our submission, we have several ways of filtering out traffic on the motorway and so on. Unfortunately, the nature of a wind farm turbine is that it moves at a similar speed to an aircraft, so filters that filter out road traffic and non-moving obstacles such as buildings cannot be used to filter out turbines.

In answer to the second question, I will cite an example. I have recently removed our objection to a wind farm site 2.5km from Glasgow airport purely because it is in a position where, although it will show on radar, it is within the aerodrome traffic zone, where aircraft are either working visually or on the instrument landing system. That turbine will not interfere with either.

I have a couple of questions for Mr Knill of the CAA. You mentioned in your submission two concerns, one of which was physical obstruction and one of which was

"Communications, Navigation and Surveillance … Facilities."

Could you give the committee some idea of the split between those two when the CAA feels obliged to lodge objections to wind farm applications?

To date, the CAA has not filed any objections, because the pre-notification of any development goes to the service provider or to the aerodrome operator and is for them to assess. We are concerned about the cumulative effect throughout the UK. Odd wind farm developments in themselves might not cause a problem to the whole airspace structure and its supporting surveillance facilities, navigation aid coverage and so on, but a large proliferation of developments could cause a major problem, at which stage the CAA might have to consider objecting. We monitor overall development throughout the UK carefully.

First, on physical obstruction, each aerodrome operator is responsible for safeguarding the area around its airport. The operator lodges plans with the local planning authorities that show areas within which it must be notified of any physical development. If the height of a proposed development penetrates the surfaces around the aerodrome—which are inclined to allow for the approach paths in and out of the airport—the operator will raise an objection in order to ensure that there is no physical intrusion into the paths of aircraft coming into and going from the airport.

Secondly, aerodromes and on-route service providers have radar and navigation facilities. We examine whether a wind farm causes interference on radar—which David Hilton has discussed from the NATS perspective—or whether it can affect the propagation envelope of a navigation aid; that is, the signal pattern that is radiated for the use of aircraft that are navigating on the on-route structure.

At this stage, most work is concentrated on the radar, but with the DTI we have started to commission extra work to examine the effect on navigation aids, not because to date we have identified a major problem, but because it is important for the CAA and our service providers that we understand what effects there may be so that we can advise wind farm developers and the DTI if there are additional issues. That work may also help us with the guidance that we can give, because it may enable us to identify ranges from such facilities within which we would not want to see a development because of the effect it would have on navigation aids.

In terms of your approach to potential wind farms, which of the two categories would be more problematic?

They would both be problematic. The service provider at the aerodrome has to be able to ensure that its operation is safe. That has to be documented under its safety management system, and it has to be able to put in place measures that would mitigate the effects of any developments in the area, such that our safety regulation group, which gives approval for the aerodrome operation, is satisfied that it is safe and that the air-traffic service provider has taken all issues into account.

That is the physical side; the same rules apply to communications, navigation and surveillance. We need to be able to satisfy ourselves that the service provider can still operate safely. That does not mean that there cannot be a development within 30km—it does not mean that there can be no agreement to developments wherever—but the service provider has to be able to demonstrate that it can still satisfy the legal safety requirements on the service that it provides. For us, they are equally important.

I have one final point on your submission. It refers to the safeguarding policy, which seems to apply only to physical obstructions. Is there a similar policy in respect of communications, navigation and surveillance facilities?

Technical safeguarding is a similar process. Physical safeguarding is more clearly defined because—as David Hilton said from the NATS perspective—it is possible in physical safeguarding to define clearly a geographical radius around an aerodrome. CNS facilities can experience interference or be affected at much greater ranges because of the effect on the airspace structure above where the interference is caused. Therefore, technical issues tend to be dealt with more on a case-by-case basis. However, a similar process exists. We keep an eye on all developments and we determine how they would impact on all CNS facilities throughout the UK. We do that in conjunction with on-route service providers, such as NATS, and with individual aerodromes.

Mike Watson asked about planning and overseas territories. It is worth bearing it in mind that airspace structures in other states are slightly different to that in the UK. Countries tend to have different ways of designating airspace and the requirements within it. In Europe, we are working under the single European sky project to change that situation and to create a common airspace structure.

We believe that, under the planning rules in Germany, if no justified objection is raised to a wind farm development it will go ahead. However, if it is subsequently found that the development causes a problem for an air-traffic service provider at an airport, the developer is required to remove the wind farm. We understand that that has happened in Germany in the past couple of years. Germany has slightly different planning rules that allow such processes to take place. There is both an airspace structure issue and a planning rules difference.

I have a question that is inspired by that point for either Mr Baillie or Air Commodore Bryant. Are any RAF planes based at air bases in Germany at present?

No, there is none based there permanently. We have come back from Germany.

To chip in on the earlier question, despite the fact that we, Germany and others are all members of NATO, we do not do things in quite the same manner. NATO has baselines, but we like to aim a little bit higher than the baselines.

I represent the Highlands and Islands, an area that is far bigger than Belgium and which contains a major low-flying area in the centre that must be entered and exited. As well as the low-flying area being an inhibitor to renewable development, all the areas of access and egress are also inhibitors. There are also the Tain and Cape Wrath bombing ranges and so on. A lot of people set store by the fact that our area has the best potential in Europe for renewable energy in wind, wave and tidal power. My questions are set against that background.

Mr Baillie said that he did not come with any statistics in respect of the MOD estates. It would be helpful if he would provide the committee with a list of places where objections have been made to wind farms before, during and after the planning stage in the Highlands and Islands and, by extension, throughout the rest of Scotland.

We will be happy to provide that information.

Thank you.

I live in an area in which a wind farm has operated for more than five years. However, a proposed extension cannot take place on the ridge at Novar because it would enter the low-flying training area. That is stated on the planning application, which is before Highland Council at present. Have you made any efforts to accommodate existing developments that would be made more economic by being extended?

Low-flying areas are not no-go areas for wind farms. Indeed, we have approved applications for developments in some of those areas. The extension of an existing development falls within the same category. We would have to work with the developer to see whether there were issues and how we could get round them. Proliferation is of particular concern. Although we might be able to approve one, two or more masts in some locations by finding a solution to our concerns, extensions can take us to the point at which that is no longer a viable option, which is why we consider all applications individually and on their merits. We seek to ensure that we give a full explanation to the developer about what we can and cannot do, and why.

The fact that the extension would be in the main line of access to the Tain bombing range would, of course, have a major effect. Nevertheless, an area that has already been somewhat developed has to take avoiding action by having the towers lower down the hill, which is an effect that the MOD has had on economic development in the Highlands and Islands. Can you quantify the effect that rejection of wind farm applications in the Highlands and Islands has had on the development of that important modern renewable energy?

It is important to make the point that we object only when there are safety matters that would affect our operations or when we can prove that there is a case to be made that there would be degradation of defence capabilities as a result of a proposal. That is the balance that we take into account in how we approach the developers and in how we seek to find solutions. If we cannot find a solution, we just have to be honest and say so. If a point is reached at which a proposal needs to go forward, that is probably when it becomes a decision for my minister to make in the balance of UK interests.

I would like to extend this line of questioning to offshore developments. We are now involved in the development of wave and tidal power, which will obviously have effects on sea lanes and on areas where submarines and ships go to exercise offshore, in what are perhaps some of the best operational areas for wave power. You say that you are currently only at the review stage of the process by which the MOD will assess how it will respond to the development of commercial wave and tidal power. If any of you have an interest in that, can you say a bit about it?

We will clearly have an interest if a development is proposed in an area in which we currently operate, whether it is our Navy that operates there or another. Again, the same principles apply as are applied onshore. We would need to understand the proposal and how we could work to achieve it. That could mean changes in some of our operational patterns, but if we could not do it that way we might have to find some other way or, ultimately and regrettably, we might have to stand up and say that we could not change.

Basically, what we are positing is a direct clash in some areas between UK defence interests and the development of the best potential renewable energy areas that we have in a country where there are not large numbers of economic options.

I like to think that we would find a solution before that was the case, but ultimately I have to agree that that could be the case.

How soon will we have the guidelines for the offshore area that I have just been talking about?

As I said, the guidelines are exactly the same as those that we operate onshore. We will operate with the DTI and other bodies, pre-application and pre-consideration, to see what we can do to mitigate our concerns effectively before matters progress.

We have a map before us that shows the two designated low-flying areas. Is it fair to say that there are other areas, including the ones to which Mr Gibson referred, in which there is also regular low flying? Is such flying associated with the various bombing ranges, for example? Would it be possible for us to get maps of all the areas where you might wish to examine applications, beyond the two designated low-flying areas that are shown on this map?

The two designated areas are the principal areas in which low flying occurs. There are some areas round about the bombing ranges for which we could provide mapping.

Your concerns would, I presume, be as relevant to those areas as to the low-flying areas.

Indeed. There are effects wherever we do low flying outwith the main transit routes. In some recent cases, we have found that the air defence radar gives rise to more concern in terms of location than does the low flying in some of the locations next to the coastal bombing ranges that you mentioned.

The implication—as far as I am concerned—is that it is just the pink areas and the green areas on the map that you provided that you had specific concerns about. Would it be fair to say that there is a considerably larger area of Scotland in relation to which you would want to be consulted in detail on any applications?

We are consulted on all proposals that are made in the UK. Our concerns rest principally on the two low-flying areas, but the fact that we are consulted on all proposals, through the process that we have set up with the wind energy industry, allows us to ensure that if concerns arise in relation to safeguarding other defence establishments, we can make them known. Our concerns are not only about the low-flying areas, but the low-flying areas do give rise to particular concern.

Is there a differential rate at which you reject proposals at the pre-application stage between the low-flying areas and the other areas about which you are consulted?

As I said, I do not have statistics that are split in that way. I can only return to what I said earlier; we deal with each case on its merits, and the areas of particular concern are the low-flying areas. Clearly, it is easier to give a technical assurance that development outwith those areas will not be as problematic.

I can give an example. An 80m diameter wind turbine, which takes the blades up to 300ft, would impact on someone in the low-flying system, but would not impact on the technical training areas, although in those areas flying can be as low as 100ft for short periods in special circumstances. Within the rest of the low-flying system, which is from 250ft up to 2,000ft, something at 300ft would have an impact. A single impact at a point in the area, all other things being considered, would not be a big issue. Low-flying traffic could be routed around it and still achieve its mission. There would be a concern if a large wind farm was put up in the middle of a choke point, where we try to fly between two towns because we do not want to fly over a population. If that gap is closed, the traffic has to move elsewhere. Would that create a problem in the area to which the traffic would be diverted? Would we start to concentrate traffic elsewhere? That is a consideration on which we would take a view, although that is not to say that there would be an objection. That is an example of a circumstance that falls outside the straightforward technical training areas.

My question was prompted by an application that exists for a sizeable wind farm near the former aerodrome at Boyndie in Banffshire. I am aware that low flying takes place in that part of Aberdeenshire, although perhaps not down to 100ft—or, at least, it is not meant to go down to 100ft.

There are concerns about the implications for radar, but the towers are static and, presumably, you are trying to identify things that are moving rather than just going round and round. Why is there a technical problem with differentiating between them, unless you might think that there is an invasion of hostile hovering helicopters?

I suspect that we might not like the technicality of the answer.

Brian Adam is absolutely right. If we were looking at a shipping radar, which is a straightforward paint of the world around us, we would know that the turbine was static. However, the turbine modulations that come off the large propellers can force a radar to think that it has found a moving target. Even if the radar is meant to detect aircraft and other moving objects, the velocity that is put on the returns that encounter the propeller means that they are bounced back by something that appears to be moving at speed. Because the propeller is turning, the radar gets a return from that bearing with a velocity that can cause confusion.

Given that the location of the turbines and the speed at which they turn will be known, and given that most facilities will have an idea of what the wind speeds are in the various areas, is there no prospect of a technical solution to what seems to be an unreasonable technical planning blight? For a layman such as myself, that seems difficult to understand.

Existing radars have what we call the ability to black-spot areas, which are known by the technical term "non-initiation areas". By inputting the latitude and longitude of a wind turbine, we can tell the radar software not to generate a return for any hits in that area. However, we would not use that method in a large area. Although it might be suitable to black-spot a single turbine or the M8 changeover so that we can get rid of a lorry that is sitting on top of the M8, that does not work for wind farms that might have upwards of 40 turbines. The proposed development at Whitelee would have 140 turbines. Blanking out such a huge area would get rid of returns not only from the turbines but potentially from aircraft as well. Obviously, there are safety considerations.

The MOD submission says that you handle applications on a case-by-case basis, but that is not what happens in practice, given that you also say that you have called for a moratorium on all developments within a radius of 30km around Eskdalemuir. That is not a case-by-case approach but a blanket ban. Press reports suggest that the area to which the proposed ban would apply has changed in size. Having gone up and down, the limit is now at 30km and it has moved a fair bit. The ban would place a moratorium on a fair percentage of the best sites for wind development in southern Scotland, when one takes into account wind speed, height and access to the 400kV grid. That is a large obstruction.

Developers are told one moment that the MOD will raise no objections and the next moment that it will. One or two developers have reported to me that they receive changing wisdom from you. Developers feel that the MOD's attitude is obstructive. Why cannot a map be produced for developers to show them where there might be a problem, where there definitely will not be a problem and where there definitely will be a problem?

We have considered on several occasions whether such a map might be produced, but we felt that it was genuinely not feasible as it would not give the best information. We would end up with amber and red areas across the country and not many green areas, especially in the parts of the country that we are talking about. That is not to say that we have given up on the idea. We are reconsidering whether, as terrain mapping improves, we might be able to find a better way of representing the issues.

A new reason for objecting to the development near Eskdalemuir hit us just before Christmas, when we began to realise within the department that the noise that the turbine blades would generate would affect the Eskdalemuir station. That is why we reacted by asking for an 80km area, which has now been reduced to 30km. We have done a lot of work with the British Wind Energy Association and the industry in general to try to find a solution that will take that forward.

For the moment, the limit is 30km. Although the restricted area impinges outside to a small extent, that 30km is, by and large, contained within the low-flying area. We are still taking a case-by-case approach. We will lodge an objection on those grounds but, nevertheless, we will work with developers to find a way forward.

There is on-going work to try to resolve the technical issue over whether there is a case for maintaining a ban for Eskdalemuir. Work is on-going with Keele University, which did some of the original work on the Cornwall study. We hope that by September we will have a positive way forward. Either we will have a way of protecting our interests—which is not necessarily a ban—or we will know that we do not have the problem that we perceive we have.

To use a traffic-light analogy, if your position is that there are no green areas in Scotland—that is, areas within which you would not have problems with wind farms—it might be more honest if you came out and said that, rather than hiding behind addressing matters on a case-by-case basis.

I ask you to focus on Eskdalemuir. Surely once a wind farm is up, any low-level, low-frequency noise that it generates will more or less be fixed in relation to the wind speed. It surprises many people that you cannot tell the difference between a nuclear bomb going off somewhere in the world and an increase in wind speed from 20mph to 30mph at Eskdalemuir. Surely there will be a method of calibrating your equipment so that it can tell what is normal, given the wind speed, and what is a bomb going off.

I share your hope that we can find that method. That is exactly what we are trying to do. The work that is going on seeks to determine whether the problem is of the size that we believe it could be, and what we can do to mitigate it.

I will take that as an answer.

I will expand my area of questioning to pick up what Rob Gibson said about wave and tidal power. Paragraph 11 of your submission is all very encouraging. It says:

"these methods of producing renewable energy are unlikely to cause MOD major problems".

That is much like how you say you support wind energy development. You then go on to qualify that by saying that such developments might cause you major problems if they were in positions that

"would interfere with military exercise areas or would be damaged by the testing of military equipment"

or if they were in range danger areas.

A large amount of the coast and a large area of the sea are occasionally used by the Royal Navy for military exercises. Are you in a position to produce a map of the coastal areas around Britain—and around Scotland in particular for this inquiry—that shows areas where you would object to any marine development?

I will take that under advisement and write to you with an answer, because I do not have an answer at this time. However, what we say in our submission is surely only sensible. We do not know what proposals will be made. Our position is that we will work with people to try to find mitigations that will allow the proposals to proceed. We are only protecting what we started out with, which is the activities for which the Ministry of Defence exists, in terms of defending the realm and looking after the safe operation of our service people while they are training to do that.

That letter would be useful because, if I can use a Winnie-the-Pooh analogy, you seem to be saying that Tiggers like all renewable energy developments except when they are proposed here, here or here. All of a sudden, we find a new objection to every proposed development. It would be useful for the development of marine technologies if we knew what the parameters were. There is no point in spending a large amount of money on surveying the coast to discover where the best places are to put marine technology if the MOD comes along the next day and says, "You can't have this or that; Tiggers don't like this or that."

I challenge that point to an extent. We are trying to get on board at the early stages so that, for example, when the coast is being surveyed for such opportunities, we are in dialogue with those who are considering the proposals so that we understand the issues and relate our issues to them. I hope that we do not come along as tail-end Charlie. I was asked earlier what we seek to do proactively. One action that we are taking is to get involved with regional and local authorities and developers to try to ensure that we understand the issues and to help them to achieve their aims.

Some developers would find it helpful were you to come on board even earlier and say from the outset where you think the problem areas are. That would avoid unnecessary waste.

There are two sides to that coin. We feel that we are doing as much as we can to help developers and we would like to do more, but we do not always get the same story from both sides.

I stress the importance of Chris Ballance's point. There is a feeling that Scotland has missed some of the spin-off economic benefits of onshore wind energy and that wave and tidal power might well provide significant economic opportunities. We would not like those opportunities to be stymied.

I have a question that is based on a layman's point of view that has been put to me. Your evidence mentions that, in the tactical low-flying areas,

"avoiding a proliferation of obstacles would negate the value of the training."

Although we do not want to make it dangerous for pilots who are in the tactical area, why would a proliferation of obstacles negate the value of the training? Surely, pilots in combat situations would not have a guarantee that the enemy had not built wind farms for whatever reason. I take the point that was made earlier that flights might have to go over either a town or a wind farm because there would be nowhere else to go, but leaving that to one side, why would obstacles negate the value of the training?

The crux of the issue is that the tactical training areas are quite small. They may not seem small when one is in a car, but they do when one is in an aircraft flying around at 450mph—it takes only a few minutes to get from one side to the other. If we closed off areas within those small areas, that would channel the traffic. The area is supposed to be unique and highly flexible. The only people who use it are those who are training to release weapons. A scenario might be set up whereby they are challenged by an air defence force. At that point, they would need flexibility to vary their route in the area, not just to go from A to B down a route that they know is clear of wind farms.

To fly at 100ft is an incredibly demanding skill. The training areas are used to practise for the real event. When we go on operations, there is a greater level of risk and we are happier—if one is ever happy about such things—for there to be mishaps. Mishaps are an occupational hazard, but we try to breed them out during training.

Do you object to electricity transmission lines or pylons, some of which are getting quite high?

I will have to take advice on that. I am not an expert on that because we tend to fly above 250ft. I suspect that the answer is that relatively few pylons go through the areas, but I will get back to the committee on that point.

My final point is on the 74km radius from the air defence radar. Your submission states:

"This policy was borne out of the tighter security employed since September 11 2001."

Does that mean that prior to that you were prepared to put up with a level of interference to the radar that you were not prepared to put up with after that date, because of the level of the threat?

The mentality used to be quite different. A little more than a decade ago, the threat to the UK air defence region, which is what we are talking about, was largely seen to be external. We were looking out for historically unfriendly forces. Nowadays, the nature of the threat is far less predictable and we might not know where it is coming from, so we do not have the luxury of being able to track potentially threatening aircraft all the way from the Kola peninsula around Norway, for example.

We have finished our questioning. I thank you very much for your evidence, which has been useful.

I move quickly on to the next panel, which is the Scottish Energy Environment Foundation. Our witnesses are Chris Bronsdon, who is the director, and Dr Gary Connor, whose position is not specified in my briefing notes.

We have talked to your organisation before so we do not need to ask you what you do. We also have your latest paper. We are obviously taking a lot of evidence and we are trying to get as many reflections on that evidence as possible before we talk to the minister in the near future.

Paragraph 3 of the summary in your submission states:

"Scotland's aspirational 40% renewables target has been analysed by using an independently verified computer model, and is deemed as being likely to be met."

That is the most optimistic statement that I have read for some time. Will you expand on that to start with?

Certainly. In order to model the position in the future, we have to make certain assumptions. Part of the remit of this inquiry is to examine what is required to bring on renewables. The current system for Scotland operates under the wider UK framework. On that basis, we have considered how different technologies will compete under existing conditions, but we must bear in mind that those conditions might not carry through to the future. For example, there might be changes to planning and support mechanisms or there might be a change of Government. We have assumed that a certain number of conditions would be steady and then, on a competitive market basis, projected what would be delivered. On that basis, the target for Scotland could be met, but that statement is crystal-ball gazing, to a degree.

Scotland makes up 10 per cent of the UK electricity demand. Given that we have the better resource and a more favourable planning system, the UK renewables obligation for 15.4 per cent of electricity from renewables by 2015 will create pressure in England and Wales to site in Scotland. Therefore, it is likely that large capacities of wind power will be forced to come north, which will make up the 40 per cent target.

I will not embarrass you by asking you what political changes you factored into the model.

In the next paragraph of your paper you say:

"Up to 90% of the renewable capacity built under the existing …"

renewables obligations

"will be wind, mainly onshore."

How much of the 40 per cent renewables target will be met by wind?

That statement refers directly to the 40 per cent target, not in the UK but in Scotland specifically. Given what market conditions are likely to produce in a Scottish context under existing policy—no policy change is planned at present—we forecast that rational investors would invest in 90 per cent wind power capacity up to 2020.

Translate that into wind farms or pylons under the latest technology.

Table 1 in our submission lists megawatt capacities.

I was interested in the column in table 1 on estimated full-time equivalent jobs. Overall, your figures for jobs created seem more pessimistic than the ones that we have seen. I am concerned about what was said about there being 72 jobs generated in the marine energy sector. Presumably that refers to what will happen if we do not invest in marine energy in the ways that you suggest later in the paper.

I am aware that you are referring to the UK gap analysis that has provided expected figures for Scotland. Our figures are slightly more optimistic to a degree, but our model has considered a slightly larger capacity of technologies being delivered in Scotland than the gap analysis allowed for. It is important to note that Oxford Economic Research Associates carried out a piece of work for the renewables innovation review that was published a couple of weeks ago that considered a similar position and validated to a degree the scenario that we produced on the predicted megawatt output.

Our view is that there are real job opportunities for Scotland, but given the existing scenario it is unlikely that the market will deliver a significant capacity in Scotland. That is not to say that there are not great opportunities for marine technology in Europe and worldwide. However, we need to show that the technology can work in Scotland first, which requires support for employment and skills.

So on the whole there is more potential for jobs than what you outline in the table. I read with interest what your submission said about more incentives through renewables obligations for marine energy. You also talked about research, design and demonstration funding. Do you see that funding as primarily more DTI and Executive funding, on top of funding for the schemes that we have seen already, funding for academic research, or a combination of the two? Will you expand on that?

Sure. The position is that to get any technology into the market takes not only the skills base and research infrastructure but the market pull and the demonstration opportunities to prove that the technology does what it says it does and that it is economic and presents a low risk. When all those things are set up, the right environment is created for a really vibrant industry and a skills base to tie in and get investment.

The electricity market in the UK is driven by the regulator, which says, "We are happy to see anything move forward as long as it is at least cost to the consumer." As a result, the cheapest technologies are generally chosen. As Richard Baker rightly said, emerging technologies might require further support to make them viable and provide real benefits. The position that needs to be taken—I am not sure that we can qualify this—is that it may be more applicable to provide research funding and demonstration funding through a different mechanism than to place additional costs in the market where the regulator is saying, "We want the least-cost technology." All we really want to alert you to is the fact that there are a number of options and mechanisms that can be explored, even with reference to what other countries have done, but you need to consider carefully whether you are trying to achieve more technology by supporting it through the market or by funding it at a higher level through other funding streams.

In paragraph 7 of your submission, you consider the less-developed technologies and refer briefly to biomass and marine technologies. Although you go on to talk about marine technology, you do not say anything more about biomass. Will you comment on that?

One of our roles is to act for the research councils in the United Kingdom through managing one of the Engineering and Physical Sciences Research Council's research programmes on sustainable power generation for wave and tidal technologies. We took the information on marine technology from an area with which we are particularly familiar, but we could equally produce the figures for biomass. I do not know whether my colleague would like to add anything on that, but if you would like further evidence, we are more than happy to provide it as a written response.

Perhaps we concentrated on marine technology simply because the export market and the potential for manufacturing and employment are probably greater than those for biomass. Finland, for example, already has a developed market for biomass. That is not to say that biomass is not applicable to Scotland meeting the 40 per cent target; we believe that it is.

In your previous answer, you spoke about the regulator seeking least cost to the consumer. Is there an argument for suggesting to Westminster that that aspect of the regulator's function be reconsidered and modified slightly?

If we are to move forward, we need to identify what we want to achieve. Scotland is taking a great step with its aspirational 40 per cent target and people's willingness to consider the issues. The committee's inquiry focuses on renewables, but the topic of renewables goes wider than the technology: it involves the skill base, social benefits, economic growth and the fact, which we must not forget, that we are working to a longer-term United Kingdom target of a 60 per cent reduction in CO2 emissions by 2050. Without the proper analytical approach, we cannot make strategic decisions about where our efforts would be best placed. We endorse such an approach being advanced in tandem with the UK Government, because Scotland is working within the framework of the UK. It would be great to see Scotland leading the UK and encouraging the DTI to adopt a supportive approach.

I think that that might have been a yes.

I too will ask a bit more about paragraph 7 of your submission. We have heard on various occasions that it seems as though Scotland and Portugal are leading the world in wave and other marine technologies and that Portugal has the leading edge in developing those technologies. However, nobody has actually outlined to us what Portugal is doing to gain that lead. Do you have an analysis of that?

We can provide a quick response.

To put it simply, Portugal has put in place a feed-in tariff for the first 20MW of wave or other marine energy. That tariff is set at €225 per MWH, compared to the £60 per MWH that we get from the ROC market at the moment. You can see the differential. A marine energy developer would look at our £60 against whatever the €225 would be in pounds. The tariff is complex and varies over time; it consists of about three pages of formula. I will not go into it now, but I would be happy to furnish you with that information, if it would help.

We can pass over the detail.

As previous witnesses have said, given our resources, we have a real opportunity in Scotland, but if we are not careful, we could lose the technology to another country that has a better market condition. That is one of the areas of work that needs to be explored further. If we are going to support emerging technologies better, how can we do it to ensure that the research base is supported, that the industry gets the right signals to invest in a home market and that we can export, too?

Is the tariff, or ROC, system more important than the research and development element? If you wanted to use one mechanism to stimulate the industry, which would you prefer to use? I realise that that is a difficult question, but the committee has to make a decision about where the balance should rest when it makes its recommendations. I am interested in where you would strike the balance.

The ROC system is extremely important for mature and market-ready technologies. Its great benefit is that investors can operate within the market with some certainty that there will be a ROC price over a certain period. In the Portuguese system, one is guaranteed a certain price over a certain number of years; however, that would not be the case in the ROC market. The Portuguese system is therefore far preferable for new and developing technologies that are only just making a profit.

The issue of research and development moneys is slightly separate, as initial investment is required in the learning rates to bring the technology to the point at which it can be profitable in the ROC market. As a result, both mechanisms will be needed.

Members have asked you questions about paragraph 7 of your submission. However, in paragraph 8, you ask yourselves some questions. Would making some short-term sacrifices over renewable goals and the first stage of reducing carbon consumption have long-term, sustainable economic benefits? It appears that the dash for wind is replacing the dash for gas. I do not know whether that is in the public's long-term interest, but we might have to make some short-term sacrifices if we are to achieve those goals. Can you quantify those sacrifices? Is such a priority more important in the long term if we want a sustainable industry?

If we are considering a move towards a more sustainable generation mix for Scotland and the UK, we will need to examine the trade-offs involving energy, the environment and the economy and will need to demonstrate transparently, through rigorous analysis, why we have chosen a particular policy direction in future. At the moment, I do not believe that we have completely brought that together in Scotland. Although we commend major steps such as the establishment of the forum for renewable energy development in Scotland—FREDS—and the opening of the first wave and tidal test centre in Orkney, and although we are aware that a lot of people are very keen to support such developments, we need to bring all that work into some strategic focus that allows us to start answering questions from an analytical perspective. The outputs of such a decision would provide the committee with what we believe would be the best option for Scotland. Although we have carried out a simple analysis, I would not say that we have answered all the questions.

I have a brief supplementary on that response, which touches on the key question that has increasingly come to my mind during this inquiry. You referred to building on the steps that have been taken and bringing things together to provide a strategic focus—although I would probably use words such as "momentum" or "pace" in that context. I want to edge on a little further. As an organisation and as individuals, you are very close to much of the work on and many of the discussions about this subject. How would you want the issues to come together to ensure that a year from now we are not still talking about all the questions that ought to be asked and all the things that ought to be done but have tried to make progress at an appropriate rate?

You are asking how we bring together as a single issue a number of the areas that have been quite rightly developed, to ensure that the committee approaches the matter with a common understanding. Those areas have to be linked up.

When the inquiry was established, I asked about the number of members of this committee who also sit on the Environment and Rural Development Committee. The longer-term strategic picture means considering global emissions and what will provide the best opportunity for CO2 reduction. Going back to Brian Adam's question, if we sacrifice something in the short term, we must be sure what that would achieve in the longer term. Several groups could be brought together to facilitate joining that up, but additional support would be required to provide an independence of view. I cannot state specifically at present what we would recommend for the future.

So you do not think that a body such as FREDS will get us there by bringing the key players together in the same room.

We believe that the FREDS is a good start, along with the establishment of the intermediary technology institute for energy, which is considering the opportunities for the commercialising of research. We are starting to coalesce good signals into a strong body of individuals who understand the market position and the investment required by industry. We must further analyse what policy options there could be for Scotland and what their impacts would be. We would then take that back to the research community and say, "We now have a number of options that we can chose, each of which has an associated impact. How can we use the expertise we have in industry and academia to get us there?" We need to be sure that ultimately we can deliver.

I have a couple of final, quick questions. I asked you a question about translating wind energy into the number of wind farms or pylons because people tend to ask that question and it is what concentrates objectors' minds. However, when I looked at table 1 in your written submission, to which you referred me, I found that it refers to megawatt capacity. Is that the theoretical capacity or is it the capacity after assuming a particular load factor?

That is the overall capacity.

That would be the capacity if the blades were turning 24 hours a day.

Correct.

Right. I am with you. So I can divide that capacity by the current most efficient pylon megawattage and get the number of pylons that your megawatt prediction covers.

Correct.

Does the 130MW for large-scale hydro in your table refer to one scheme?

The way in which the appraisal model works is complex. We can provide that information separately. The model sums up the total number of megawatts and does not indicate whether they are from single or multiple projects.

You heard the MOD's evidence. Have you factored its position into your model?

That can be factored into the model, but I am a little unclear about how we would do so. It is the same with planning and transmission, which involve loss multipliers and other factors that may have a negative impact.

You told us that you assumed that there would be a benign planning system. You could hardly describe the MOD as benign—with due respect to the MOD witnesses, if they are still listening.

In order for the model to stand up, we worked from published data and statistics for planning success and build rates. The information that the model produced accurately reflects the market, which ultimately delivers the investment and the capacity on the ground. We think that the committee should be aware of that. We have a fantastic resource, a willing industry and a good skill base that can be encouraged to expand into the renewables area. However, the market will ultimately deliver the capacity. We must consider whether we can influence policy options and the required discussions or whether we should look outside the market construct for delivery of that.

When we have the minister in front of us, is there one killer question that we should ask him? Not that it would be a killer question, because he would have read it in the Official Report of this meeting by the time he appeared in front of us.

That is a good question.

You can write to us if you do not want the minister to see the question in the Official Report.

I will pass on the question for the time being. We might provide a considered response in writing.

Okay. I thank you for your evidence and I apologise for the lateness of the hour. Your written submission is meaty and will repay further consideration by the committee.

Meeting closed at 17:24.