SNH Rethink Wind Repowering Stance

Wind Repowering is a simple concept made complex by planning. But a recent change in position from Scottish Natural Heritage (SNH) could make the planning process much simpler and have an enormously positive impact on the industry.

Repowering a wind farm involves replacing ageing turbines with new ones on the same site. These new turbines are more efficient, sometimes larger, and have the potential to increase generating capacity and extend the life of the site. It may also reduce the number of turbines at the site.

The benefits are obvious. The repowered wind farm can utilise the existing infrastructure, such as foundations, access roads and substation, greatly reducing the cost and disturbance associated with construction.

Wind repowering could be a key element in meeting renewable energy generation targets and the practice is recognised and broadly supported by the Scottish Government, who state in Scottish Planning Policy (SPP – paragraph 174):

“Proposals to repower existing wind farms which are already in suitable sites where environmental and other impacts have been shown to be capable of mitigation can help to maintain or enhance installed capacity, underpinning renewable energy generation targets. The current use of the site as a wind farm will be a material consideration in any such proposals.”

That last point, about current use being a material consideration, is key to the planning issue.

SNH current position on wind repowering

Until now, the position of SNH when considering a planning application for a repowered site has been that “the formal baseline for EIA (Environmental Impact Assessment) should be the expected restored state of the site, excluding the existing turbines.”

This view was contained in the draft guidance SNH provided last year on how they would consider repowering applications, confirming that they would consider repowering applications against a baseline where there are no existing turbines. Locogen subsequently liaised with Scottish Renewables to provide a robust response to SNH’s consultation on the matter, which identified the following key points:

  • The majority of developers will be submitting repowering applications while existing wind farms are still operating and have a few years left of consent. Therefore, using the restored site as the baseline would not reflect the actual case on the ground with the ‘do nothing’ approach being the existing wind farm.
  • The baseline for any application should reflect the existing use and the existing wind farm provides a good evidence base for assessing the impacts of a repowering proposal.
  • Repowering existing sites allows developers to re-utilise existing infrastructure and this again reflects the site in its current form (i.e. existing wind farm in place) being a material consideration

Results of wind repowering consultation

SNH has published the responses to the wind repowering consultation on its website, along with a brief analysis of points raised. We are delighted to see that SNH have taken onboard the above points and that their published guidance states that they will now consider the planning baseline to be the existing windfarm.

SNH is now reviewing the implications of their new position for their broader guidance and will publish updated information in due course. On February 6th they will host a workshop for a small group of representative stakeholders, including the Scottish Government, to work through the impact of these changes.

This is an important decision. Repowering of the UK’s existing wind farms towards the end of their operational life is seen in the renewable industry as an efficient means of using the latest turbine technology to maximise the cost-effective delivery of onshore wind. Typically, repowering will have the potential to decrease the overall number of turbines (by using fewer, larger turbines) and can also significantly increase the site’s generating capacity whilst not increasing the overall footprint. The number of sites that will be considering repowering will rise dramatically over the next 5 years as early wind farms come to the natural end of their operational life. This could could offer a significant route towards meeting renewables targets.

An excellent result for the industry, the environment and consumers alike

With intransigence in negotiations currently dominating the news, it is refreshing to see the willingness of SNH to conduct a proper consultation, consider the responses carefully and be willing to change their stance. They should be congratulated for this.

Thanks, also, to Stephanie Conesa and the team at Scottish Renewables for producing a considered, comprehensive and, ultimately, convincing response to the SNH consultation. This provides a great opportunity for the industry, bill payers and communities to continue to benefit from “one of the lowest-cost, scalable electricity generation technologies in the UK”.

You can read the SNH consultation here, and the Scottish Renewables response here.

Please contact us if you would like more information on life extension or repowering of wind farm assets.

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