A UK local authority in Warwickshire recently rejected an energy firm’s attempt to extend the operational life of a solar farm from 25 years to 40 years. This mirrors the controversy in 2017 over the proposed extension to Kirkby Moor wind farm, a debate that is still ongoing. However, according to Michael Phillips, Principal Planning Consultant for Dulas, these two instances are just isolated examples in comparison to a much broader support for renewables among UK local authorities. Nevertheless, the real threat to clean energy in the UK comes directly from government and its attitudes to renewables since the Conservatives entered power in 2010 as part of the Coalition.
Mr Phillips explained to REM the various challenges that currently face the UK industry as developers attempt to extend the service life of wind and solar farms, the processes involved, and why, with the continued failure by the Government to support the onshore wind industry, the prospects of repowering and extension are under threat. Philips also explained what must be done in order to ensure that the fight to maintain a key role for renewables, particularly onshore wind and solar power, as part of the country’s general attempt to counter climate change, must be won.
Can you introduce yourself and say a bit about your company, Dulas
I started at Dulas in 2001, so I’ve been here for around 18 or 19 years and worked my way up to the role of Principal Planning Consultant, so I head up the team that deals with new greenfield development – whether that’s wind, solar or hydro. In effect, we engage in services to do with site finding, site origination, site refining, design, planning, EIA and then post-development, but it’s typically, once the scheme has got to the end of the planning process and before it goes into pre-commencement procurement, we take the project pretty much right the way up to that point.
The team also works with wind monitoring teams in terms of getting the masts in the right position so we provide a composite service to developers that cover all of their needs through that initial development phase.
Can you give me a bit of background with regard to extending the life of wind and solar farms.
In terms of life extensions, I have dealt with a couple of Irish solar farms where they’ve sought extensions to their planning periods of 25-30 years, and I understand the principles involved. It’s not just a straightforward process of going through your original planning permission, digging out the condition that refers to a 25-year operational period prior to decommissioning and then applying either Section 73 or Section 75 for a variation to that condition. That condition was predicated on the basis of an original conceptual design and built design for the wind farm and a lot of things have changed over the last 15-25 years since those schemes were originally built. There may be some material planning reasons why councils would have concerns, but also they don’t tend to like the Section 73 or Section 75 amendment approach for extending projects. I’ve still not managed to get my head around why that isn’t an acceptable approach, particularly if you support that application with a supplementary environmental report that deals with some of the planning issues that may arise through an extension of that project. You should be able to deal with it fairly comfortably through the Section 73, Section 75 approach. Planning officers are pretty opposed to using that route for extensions on projects.
So that’s my perspective from the planning angle.
How much can you tell me about instances such as the Warwickshire solar farm and the Kirkby Moor wind farm?
I don’t really have too much to add on those two instances. They make good headlines because of the drama involved, but also we are overlooking around 23 other cases where extensions, repowering or lifetime extensions have been agreed by local authorities. The percentage majority shows that local authorities actually are supporting repowering and extensions, but it’s easy to draw out a couple of examples where local authorities are shown to be failing.
I haven’t seen the decisions or notices relating to those schemes, so I can’t really cogitate on whether they are valid planning refusals, which I doubt, because the planning officers did come through with recommendations for approval, so again we have this disconnect between officers and councillors, with councillors believing they are acting on the interests of their constituent members but really being influenced by those small minorities using hysteria and unfactual information to undermine any faith in wind farm technology itself. The officers often know what they are doing. It’s the councillors who are often working from an emotional level who are refusing the scheme.
Can you then give me a background to repowering in the UK and what the main challenges are?
We have got some direct experience of that. We were engaged by Good Energy for the Delabole repowering, that was a design job, working with the landowners, Peter and Martin Edwards. So there are a vast array of additional wind farms, the majority in Cornwall and up in the North East but also in Wales as well, that have got to the point now of where not only the turbines are starting to reach their end of life period but there is also interest from the operators to try and triple the installed generation, the installed capacity and also try to triple the output and therefore triple the benefits. Those benefits are in fossil fuel emissions and carbon dioxide savings but also the operators are looking to a route to market whereby they can increase their actual income generating opportunities on those sites.
We’ve been asked to quote on several sites but only won one which is the Good Energy at Delabole. There are considerable benefits associated with the repowering, both in terms of increased carbon dioxide savings, you’ve got the opportunity for improving performance of the wind turbines and improving the output, hopefully you get a better reliability and availability of the turbines because they will be modern manufactured turbines and new off the factory shelf. So, there are considerable benefits in repowering these sites. In the case of Delabole, we were able to triple the existing capacity of the site, well, not quite, slightly less than triple I think, through replacing the 400 kW wind turbines that were on site with 2.3 MW generators. I think the tip height changed from round about 65 metres to tip up to 105 metres to tip.
The difficulties you have, firstly from a design perspective, is that with the vast majority of wind farms, often they are ‘shoehorned’ into the available land holding, where you’ve got agreements with landowners for turbine deployment on their land – those land ownership options aren’t unlimited. Therefore you have a very hard boundary to work to and you have to redesign the scheme within that boundary area, unless you can get some additional landholding, but if you’re not able to, you’re working within the existing constraints of the site itself. Shoehorning wind farms into old development boundaries, particularly with new wind turbines and technology can itself be fairly complex. With much larger turbines, you still need to maintain a standardised spacing between the turbines, which is typically 3 x 5 diameter or 6 x 4 diameter spacing between the turbines. In effect, that takes up quite a considerable portion of your available land area. That leads to greater restrictions on the number of turbines that you can actually deploy within the existing site.
It’s not always a ‘no brainer’ that an existing site has the characteristics available for you to be able to ‘replant’ turbines within that available area to get more capacity, more generation and potentially just as good a return on investment as they have done historically. That shoehorning from a design perspective can be fairly problematic and challenging.
In addition to that, with much larger turbines, and I am saying with regard to the design and planning aspects of getting these schemes approved by local authorities, you’ve got additional planning issues around collision risk modelling, they have much longer blades that are much higher in the air, which may present a much greater threat to bird movements or bat movements across the site and, because of the precautionary principle that’s at play, typically now you need at least one year’s worth of bird data or sometimes that’s two years worth of bird data, depending on the sensitivity of your site. That has a long lead-in time for projects, for example. Then out the back of that you’ve got to demonstrate through your environmental report or EIA that any collision risk would only be to acceptable limits and wouldn’t breach unacceptability thresholds.
You’ve got the transport implications, with invisible loads and trying to get 65 metre blades, sometimes longer, through the highways network to a site, we know for example that where repowering and new powering forest areas in Scotland is being considered, there are quite considerable challenges to getting the new modern breed of wind turbines to a site. The cost of highway modifications and amendments sometimes can actually preclude a development going ahead. That in itself is a real headache and head scratcher that you have to deal with. Pretty much key to the feasibility, prior to design, you have to use a transport consultant to actually determine for you whether you can get those turbines to site or not. Often that can be a decision maker over what scale of turbine you can get to site and that would then obviously have an impact on the whole economic viability of the scheme.
Add then additional amenity issues, with much larger turbines and visual impact, potential noise propagation and what they used to call shadow flicker, but we can call shadowing because, to all intents and purposes, modern wind turbines don’t create a flicker effect. They do create a shadowing effect that is below 1 Hz, which is not therefore a health issue but it is still something in the planning system that you have to deal with.
In addition to those core planning issues, you also have the complexity of, to all intents and purposes, an onshore moratorium in England. As your existing wind farm scheme is within an allocated area, under the local development plan, and identified in terms of Greg Barker’s statement of 2014/15 that it has to be an area acknowledged in the local plan as worthwhile for wind energy development. Unless you are wind site is within one of those specially allocated sites, it won’t achieve planning support on the basis of that criteria. Any new wind farm proposal will have to demonstrate that public support. That is a very difficult thing to thrash out because inevitably you are going to have a minority of 1-3 people who are always going to be opposed to change with regard to any kind of new development. Therefore, getting over that hurdle, demonstrating full public support is a very difficult ask for developers in England. It’s very different in Wales and Scotland, with a much more favourable planning policy climate. Indeed, we’ve had the very real benefit in Wales of the shift in decision-making powers for all new proposals above 10 MW by the Welsh Ministers. Therefore any new repowering sites, they would have the benefits of not being determined by local authorities and being determined instead by the Welsh Ministers, which gives them a bit more certainty over the planning process and securing planning consent.
Similarly, you’ve got special guidance in Scotland and a pretty good environment. So in those two countries and in Northern Ireland, you have a much better appetite and we’re still working on schemes in Wales for new schemes for developers that have some potential, but the elephants in the room being, fundamentally, the route to market and grid connections as well. On the latter point, with a tripling in capacity you can’t be assured there is the capacity to be able to take your export and deliver to the distributional transmission network. Again, that needs to be one of the critical studies, looking at grid availability, which may determine the size of scheme that you could repower at any given site.
The route to market without subsidy support at the moment is very challenging for the developer network. We’re working for several utilities on very early stage critical path work such as wind monitoring regimes across sites, two year bird studies looking at vantage points, breeding birds, you name it. Everything that we have to survey has to be done now in a much greater degree of thoroughness to inform the impact assessment work that we do.
There are signs of investment money going into these schemes and we are certainly starting to get to the point now where these schemes will go public, having gone through early feasibility studies and other bits and pieces. We’re hoping that next month or the month after we’ll be with our clients announcing two large mid-Wales wind farm projects that we’ll start to take through the early preliminary planning process, including pre-empt consultation. So there are some promising signs, but the state of the market, the difficulty of the policy framework, currently driven by UK Government and this difficulty over some of the planning issues of repowering with larger turbines are still major obstacles to overcome.
With all that in mind, how positive does the industry look at the moment, for the near future?
I think it’s fair to say 2018 has seen one of the slowest growing years on renewable energy across Europe. I think there is a significant slowdown, despite the fact that the global need and justification for renewables has never been in less doubt than before. I am not sure I am in a position to talk on behalf of the industry but from our perspective at Dulas there is still a fundamental concern that neither finance nor policy is sufficiently supportive to roll out renewable energy and particularly wind power over the next ten to fifteen years sufficiently to start to fill the energy gap that’s left by the discontinuation of coal and gas for example.
I am afraid to say that repowering 62 to 65 wind farms that were originally installed, repowering them won’t go anywhere near beginning to fill the energy gap that’s looming ahead of us. Even with the offshore deployment, I think there is still a strong sense that you’re not going to be able to deploy sufficiently, with storage, to cover baseload requirements. So yes, we have this whole issue of energy security and whether we are going to have sufficient power to drive our needs but also I can’t see that under the current political and financial climate that we’re going to come anywhere near to deploying sufficient renewables to make any inroads towards our carbon reduction targets.
That’s really interesting given the current clamour about climate change and the demand for government to do something about it. That doesn’t sound at all positive.
I had this discussion yesterday with a couple of people and it’s very clear, right from when I started actually, in 2001/2, under a different administration, that these pillars were put in place for a very clear decarbonisation future. You had subsidy arrangements, you had positive planning policy and it felt like all the right determinants, all the right pillars were put in place to really start to deliver. Whether it was to do with power generation or whether it was to do with agriculture, all those different sectoral aspects were all being addressed at that time and it’s those pillars that have been dismantled, fairly rapidly dismantled, since 2010, since the Coalition government took over. It’s since 2010 that we’ve seen a fundamental change to our business. If you look elsewhere, we’ve spent the last four years designing and planning for large-scale solar in Ireland, which has been the mainstay of our work because the UK market has gone so quiet. Currently, it’s still pretty quiet, with a few initial positive indications of change, but only a few.
We need to have a fundamental change to those political structures in governance, because you can’t allow an international issue like global warming to be a hostage to political fortune. I think that global warming has to become a non-denominational issue that either all parties, or no parties, buy into. As well as governance change, you also need a fundamental change in political support and policy support, planning policy support and then very strong messages to the public, I think, that “you’re going to have to face an uncertain future, that uncertain future must lead to certain essential requirements which will be the temporary change of our landscapes over however many years that is necessary”.
But it’s not all bad news with regard to landscapes, for in fact wind farms are shown to displace fossil fuels significantly as part of the energy mix, and that they do have a downward force on energy prices which is in the interest of the consumer.
It is a necessity for those positive messages, unambiguous messages, to go out to the public and make sure that they are taken onboard as part of the journey towards what I hope will be, now, a new decarbonisation agenda.
For additional information:
