Climate and Energy

Stop Climate Chaos

Stop Climate Chaos is a wide-ranging coalition of environmental and international development organisations as well as women's organisations, activist groups and faith-based campaigns. The coalition aims to build an irresistible pressure on politicians to all that is needed to to halt climate change. Several LINK member bodies belong to the SCC network and there is close liaison between their campaign in Scotland and the LINK Climate Change Task Force.

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Electricity in Scotland - Transmission and Distribution
Briefing Paper - December 2005

Summary
An examination in public, either through Strategic Environmental Assessment or by a Planning Inquiry, must be undertaken by Scottish Ministers before significant upgrading of the electricity transmission system in Scotland. Major expansion of the grid should not take place without a clear policy context and proper integration with sustainable development principles.

Key Issues
Plans to develop the electricity transmission system in Scotland have been developed in isolation, with limited strategic consideration of how to sensitively accommodate new energy developments in the environment. This includes the environmental impacts of lines and pylons and the subsequent location of renewables development once capacity has been increased.

There is no clear published policy background for the development of high-capacity electricity transmission lines, and the sustainability of encouraging reliance on long-distance electricity supply needs to be questioned.
Full consideration of demand reduction initiatives and the development of alternative, off-grid approaches to delivering renewable energy is lacking in projections for transmission upgrades.

Background

The Government's efforts to reduce greenhouse gas emissions through the development of renewable energy technologies have precipitated an overhaul in the system for transmitting energy from power generation plants to our homes. This potentially raises serious environmental issues as the electricity grid is upgraded to carry more electricity, and new routes constructed to extend the grid.

There are significant indirect impacts associated with reinforcing the transmission network, in that development of the grid may influence the location of new renewables projects, potentially opening up new "energy highways", steering development into more remote and often environmentally sensitive areas as extra carrying capacity is filled.

Fundamental questions have to be asked of how to best meet the renewable electricity generation targets set by the Scottish Executive of 40% by 2020. Development of electricity generation and distribution has to take place within the context of how we use and generate energy and how CO2 emission reductions can be effectively achieved.

The Government's Sustainable Development Commission, in a study of the development of wind energy resources in the UK (May 2005), emphasised that reducing demand on the national grid was "essential" and "perhaps the most cost effective way of meeting our obligations to cut greenhouse gas emissions". In addition, a key principle should be to keep sources of generation close to where power is needed.

It would be useful, at the outset, to create a clear hierarchy of energy management in terms of overall environmental and social impacts, which would help prioritise policy implementation. This needs to start with energy conservation as the primary objective (as the SDC suggest above), followed by energy efficiency, then micro- and community scale renewables, followed by macro-renewables. Once these targets are well in hand attention may be turned to fossil fuels with Carbon Capture and Sequestration. Nuclear should be the final option.

We acknowledge that these principles do not eliminate the prospect that in shifting from fossil and nuclear sources of energy, limited grid development or extension into new geographic areas may be required. However we should optimise our use of renewable resources and take a strategic look at the grid network to move power around so it can meet our electricity needs. This requires appropriate planning controls to ensure that desirable renewable generation capacity can be connected to the grid, whilst environmental impact is minimised, and that the resource is not wasted through excessive transmission losses.

The Department of Trade & Industry's Transmission Issues Working Group in June 2003 produced a report in which a Renewable Energy Transmission Study (RETS) gave options for different scenarios of renewables energy penetration into the existing grid infrastructure. This study, when it was produced, was not open to any public debate on how the nation's future electricity generation from renewable sources should develop.

The arguments of the benefits of energy efficiency coupled with microgeneration and CHP do not appear to have been fully considered: the savings in CO2 emissions through generating power close to where it is used; the economic benefits to communities and individual consumers; the avoidance of landscape impacts from new, large powerlines; and the increased security of supply through less demand being put onto the national grid.

Recent claims by power utilities about the capacity of renewables that can be delivered with or without powerline upgrades raise questions about the way these upgrades are being handled. The case for the Beauly to Denny 400kV upgrade has been made by Scottish and Southern Energy (SSE) and Scottish Power on the basis that renewables targets will not be met without it and that there is sufficient demand from generators. Scottish Power (SP) however in submission to Ofgem have suggested that SSE can deliver 1.55GW without the Beauly to Denny upgrade and that SP have additional 2.83 GW windpower already contracted to connect in their area with up to 4.3GW available if the Western Interconnector with England is approved by Ofgem. This would suggest that there are practical alternative ways to meet the 6GW required to meet the 2020 renewables target. The apparent contradictions should be resolved before investment is committed to a particular option.

In this context, the Beauly to Denny transmission line proposal is premature as this particular proposal is not required in order to meet the Executive's 2010 target of 18% of Scotland's electricity needs generated from renewable sources. Nor is it likely to be needed for the 2020 target of 40% provided the Scottish Executive takes a more balanced approach to renewable energy generation. This should embrace more than just electricity generation, but include biomass and biofuels for space heating, along with demand reduction measures and use of clean fossil fuel generation. Any delay brought about by an inquiry would not undermine the 2020 target. Nor would a failure to deliver the Beauly to Denny line create a dependency on new nuclear capacity. We see no need for further nuclear capacity to be developed to meet our 2020 energy requirements, if these measures are implemented.

The proposals identified above for upgrading transmission lines, are taking place without adequate strategic context. Planning policy context for approval of transmission lines is missing, with no clear published policy background. National Planning Policy Guideline 6 Renewable Energy provides the planning context for power generation. NPPG 6 explicitly states that the policy guidance set out in the document is "applicable to the authorisation of electricity generation schemes under Section 36 of the Electricity Act 1989", i.e. large power generators, of greater than 50MW capacity.

The authorisation of overhead power lines, applied for under Section 37 of the same Act are not included in this published policy guidance. Given that the reason for the transmission line upgrade is specifically for renewable energy developments, then it becomes a matter of urgency to formulate and discuss a policy context for determining Section 37 powerline proposals. In addition, decisions on the desirability and feasibility of subsea cable connections direct from offshore marine installations to existing high-voltage capacity lines near to centres of demand lie outwith the jurisdiction of the planning system.

Ofgem, when considering their "economical, efficient and co-ordinated" approach to transmission line development do not take planning policy context into account. Energy policy is a policy area reserved by Westminster, but the Scottish Executive have the responsibility to plan for renewables in Scotland. This includes the contribution that microgeneration can bring to reducing demand on the grid.

Conclusions

Given the generating capacity for renewables that is claimed is available, coupled with demand reduction initiatives and cleaner conventional technologies, it is possible to meet our energy needs without going down the road to more nuclear generation.

It is imperative that we drive down CO2 emissions, but it is questionable that it will be achieved by expanding the electricity grid and increasing its capacity, without it being part of a co-ordinated plan that includes demand reduction. The Scottish Executive needs to examine how to generate, transmit and distribute renewable energy in a sustainable fashion. This may be conducted through Strategic Environmental Assessment or through a Planning Inquiry Commission, but either way examination of the options should be conducted in public.

However it is conducted it would appear that a major transmission upgrade in Scotland is premature, and would be taking place without a clear policy context as to how such upgrading should be developed in order to accommodate the renewable energy developments that would be most effective in reducing greenhouse gas emission.

This briefing was prepared by a LINK working group consisting of the following member organisations:

Friends of the Earth Scotland

John Muir Trust

The National Trust for Scotland

Mountaineering Council of Scotland

Ramblers Association Scotland

RuralScotland

RSPB Scotland

Woodland Trust Scotland

Media Release 12 October 2005

Cross-party Position on Global Warming

As the UK struggles to reduce its greenhouse gas emissions, political parties are being urged to unite in tackling climate change. In a House of Commons debate on climate change today, Conservatives and the Liberal Democrats will make the case for cross-party consensus on countering global warming and new measures to cut greenhouse gases. Scotland’s environmental groups have welcomed this proposal which could help get commitment to tackle the climate change problems, beyond the normal short term horizons of politics.

Scottish Environment LINK, the umbrella group for Scotland’s environmental organisations, welcomes the joint proposal from the Conservatives and the Liberal Democrats for tough new policy to tackle climate change. Climate Change is happening already, it will get worse and urgent action is needed now to prevent the worst consequences. In Scotland, the political parties have already demonstrated a responsible approach, with cross-party agreement on strong recommendations to reduce the greenhouse gas emissions responsible for climate change.

Fred Edwards, President of Scottish Environment Link said:
“Climate change is a greater danger to our children and our children’s children than terrorism, it threatens food security and will exacerbate the already difficult freshwater position in the World.”

Contacts:
Julia Harrison, Parliamentary Officer 0131 311 6500 or Clifton Bain, LINK Climate Change Task Force Convenor – 0131 311 6500 clifton.bain@rspb.org.uk

Notes for Editors

The proposal for a cross-party initiative has come from Norman Baker MP, the Liberal Democrat environment spokesman, and Conservative counterpart, Oliver Letwin MP. The case for tougher action on climate change will be made in a Commons debate on climate change today 12th October 2005.
The Scottish Parliament Environment and Rural Development Committee has published recommendations following its cross-party Inquiry into Climate Change.

Scottish Environment LINK has a challenging Climate Change Action Plan, please see below.

LINK Climate Change Action Plan

Scottish Environment LINK member bodies (listed below) believe that Scotland needs urgent action on climate change and highlight the following 10-points:

1. Climate Change is happening already, it will get worse and urgent action is needed now to prevent the worst consequences.

2. Scotland needs Scottish greenhouse gas reduction targets and a realistic programme to achieve them.

3. Scotland's rural, urban, coastal and marine areas are going to continue to be seriously affected by climate change. We must accept this, mitigating effects where possible and coming up with strategies which help us adapt where not.

4. As part of a Scottish Energy Strategy, the Scottish Executive should take an active role in promoting a diverse base of renewable energy schemes.

5. Transport emissions are significant and growing; an effective integrated transport policy is required to curb these emissions.

6. Scotland needs to reduce energy consumption and must implement energy efficiency targets for domestic, commercial and industrial buildings, land use and food production.

7. Scotland must safeguard its carbon reservoirs, particularly peatlands.

8. The Government needs to help people understand the consequences of the choices they make (about where they live, how they travel, what they buy etc.) and to enable them to make climate-friendly choices.

9. Scottish decision makers must play a part in international climate negotiations, pressing the UK, Europe and UN for action.

10. Only with sustainable development addressing the environment, social issues and the economy together, can we really tackle climate change.

Scottish Environment LINK member bodies, keen to contribute to these actions in Scotland, call on the Scottish Executive and on Scotland's MPs and MEPs to play their part in developing, implementing and resourcing a detailed Scottish Strategy on Climate Change which addresses these points and brings together social, environmental and business interests to reduce emissions and improve quality of life. Given the scale of the climate challenge it is vital that climate action is not delayed or weakened by shorter term, political focus.

CLIMATE CHANGE
Climate change is the most serious environmental problem facing the globe. In Scotland it will mean more unpredictable weather, more storms and rising seas, leading to floods, drought, failed harvests, the spread of disease and whole species being wiped out.

Climate Change is happening already, it will get worse and urgent action is needed now to prevent the worst consequences. From the weather disasters around the world to breeding times of birds, there is no question that things are changing, with seven of the 10 hottest years since 1961 occurring in the last decade. The more we do today to reduce emissions the less damage will happen in the future and the cheaper it will be to cope with change.

The UK signed up to climate targets at the Earth Summit in Rio in 1992 and further targets at Kyoto in 1997. The Scottish Executive has pledged that we will 'play our part' and 'make an equitable contribution' to meeting these targets but the Scottish Climate Change Programme did not set any specific targets for Scotland and specifies little actual action.

In Scotland, we are falling behind in tackling climate change. Recent Government figures reveal that Scotland's emissions of CO2 fell 5.6% between 1990 and 2002, while overall UK reduction was 15%.

Taking action on climate change will have extra benefits - as well as avoiding the worst damage from the changing weather and addressing problems already being faced in farming and fisheries, Scotland will create jobs, and reduce air pollution and related health problems.

Scotland needs greenhouse gas targets and a programme to achieve them.
Clear national and sectoral targets are needed so that everyone - businesses small and large, the public, farmers, local councils - can see what is expected of them and what needs done to meet international targets. We think that Scotland should aim for a 12.5% reduction in greenhouse gas emissions on 1990 levels by 2010, and for a 60%cut in CO2 by 2050. Scotland needs to make year-on-year progress in all sectors towards these targets, with regular reports on progress to Parliament.

Scotland's rural, urban, marine and coastal habitats are going to be affected by climate change. We need strategies to reduce the impact on Scotland's biodiversity and allow species and habitats to adapt, where necessary.
From coping with flooding to realigning coasts and from changing our farming practices to integrating planning with biodiversity conservation, we need to prepare today for the changes that will happen in the coming decades. Species and habitats important to Scotland are vulnerable to climate change because many are in a damaged condition and exist in a fragmented landscape, threatening their continued survival and depriving them of the ability to shift to climates that are more suitable.

Measures must be implemented to prevent the loss of archaeological sites, species and habitats, and help them cope with new climate regimes. Where species and habitats will have to adapt or move we must assist this process. An adaptive strategy for biodiversity would protect, restore, expand and link together semi-natural habitats and make the wider countryside more wildlife friendly. Planning for development, agriculture and forestry practices must work with biodiversity conservation to provide a landscape that is permeable to species movement. We need an integrated approach to land and sea use, to avoid losing Scotland's characteristic species and habitats to climate change

The Scottish Executive should promote a wide range of renewable energy schemes within a Scottish Energy Strategy (see LINK's Energy Statement ).
Renewable energy sources, like the wind, waves, sun and specially grown 'energy crops,' are essential in reducing emissions. There should be significantly improved planning and funding within the framework of a national energy strategy to support all renewables, including those which produce heat, boost Combined Heat and Power schemes and work to phase out fossil fuels and nuclear power. Nuclear power is expensive and dangerous, and new reactors have no place in Scotland's future energy provision. Investment in research, development and deployment of renewables is investment in clean energy, jobs in Scotland and new manufacturing industries. A challenging but achievable target for Scotland would be 50% of our electricity to come from renewables by 2020.

Transport emissions are significant and growing; an effective integrated transport policy is required to curb these emissions.
Transport, mainly road transport, was responsible for 14% of climate change emissions in 2002 (excluding emissions from land use), and is the fastest growing sector of emissions. Aviation is the fastest growing source of transport emissions. UK policy aims to cut transport emissions by 17% by 2010, half that reduction coming from measures like congestion charges and parking charges at work. More needs to be done to ensure that all transport proposals and policies contribute to reducing emissions, including an end to major, traffic-generating road schemes and measures to stabilise the growth in air travel.

Scotland needs energy efficiency targets for domestic, commercial and industrial buildings, land use and food production.
Every year thousands of Scots die from conditions related to cold, damp housing. Solving this national disgrace is now a priority for Scotland and doing it right will reduce the 25% of CO2 emissions which come from people's homes. Between 1990 and 2002 CO2 emissions from the Commercial sector rose by 35%, mainly because of increasing energy use within buildings. Energy use in the production of fertilizers, management of soil for agriculture and food production and procurement requires urgent review. The Scottish Energy Efficiency Strategy should give priority to demand-reduction, with the carrot of investment and incentive packages, and the stick of regulatory and financial measures.

Scotland must safeguard its carbon reservoirs, particularly peatlands.
Scotland's soils lock up a huge amount of carbon, far more than all the trees and shrubs in the UK put together. It is vital that these carbon 'stores' are protected through appropriate forestry, agricultural and development planning policies, an end to commercial peat mining and an urgent programme of peatland restoration. This would also help conserve their biodiversity and archaeological value.

The Government should help people understand the consequences of the choices they make and enable them to make climate-friendly choices.
The Government, industry and citizens all need to do their bit to tackle climate emissions, We can all help reduce climate change emissions at work, at home, in school, etc, by making the right choices. Government should help us to do this by making the right choice the easy choice. This means investing in integrated transport, public information campaigns and leading the way, for example by ensuring all public buildings meet tough efficiency standards and make use of renewables and/or CHP. Industry, business and commerce must also be given greater incentive to lead by example.

Scotland must play its part in international climate negotiations.
Scotland is part of the UK delegation to UN meetings on climate change. It is vital that Scottish interests are properly represented and that Scotland makes a full contribution to meeting UK targets. Scotland should help to ensure that international rules force most savings to be made 'at home', and that nuclear power and destructive forestry projects are not supported.

Sustainable development means considering the environment, social issues and the economy together. This is the only way to really tackle climate change.
Climate change should be a major consideration in all areas of Government decision making. At present, competing priorities prevent a proper, joined-up response to climate change. The key example is the drive for economic growth. If the quality of the economy, rather than simply its size, were measured, it would be clear that climate change should be a major factor in economic and business planning. Education for sustainable development is a key part of changing the way we look at problems and make decisions. The emissions reduction and adaptation responses to climate change should also be based on sustainability principles.

September 2005

Signatories to LINK Climate Action Plan

Association of Regional and Island Archaeologists
Badenoch and Strathspey Conservation Group
Biological Recording in Scotland
British Trust for Conservation Volunteers Scotland
Butterfly Conservation Scotland
Cairngorms Campaign
Council for Scottish Archaeology
Friends of the Earth Scotland
Hebridean Whale and Dolphin Trust
Marine Conservation Society Scotland
National Trust for Scotland
North East Mountain Trust
Plantlife Scotland
Ramblers' Association Scotland
Reforesting Scotland
Royal Society for the Protection of Birds
Royal Zoological Society of Scotland
rural Scotland
Scottish Council for National Parks
Scottish Native Woods
Scottish Wildlife Trust
Soil Association Scotland
Sustrans Scotland
Whale and Dolphin Conservation Society
Woodland Trust Scotland
WWF Scotland

Notes
Scottish Environment LINK is the liaison body for Scotland's voluntary sector environmental organisations. LINK was established in 1987 to provide a forum and network for the voluntary environmental sector to assist in co-operation and communication with government bodies and other bodies with a role in Scotland's environment. There are currently 36 member bodies in LINK, representing almost half a million people.
LINK is a Scottish Charity (SCN 000296) and a Scottish Company limited by guarantee (SCN250899).

Further information
Clifton Bain, Climate Task Force Convenor, tel 0131 311 6511
LINK Parliamentary Officer, tel 0131 225 4345
LINK Chief Officer, tel 01738 630804

Scottish Environment LINK Concern Paper for the Environmental Advisory Forum For Renewable Energy (EAFRE), April 2005

Introduction
Following the first meeting of EAFRE representatives were given the opportunity to submit 'concern papers' to the Scottish Executive outlining those 'bigger picture' issues, above and beyond the need review of NPPG 6, which members felt should be addressed in order to facilitate the role out of renewables.

These issues are not new. In both our energy policy statement and in the evidence we submitted to the parliamentary inquiry into renewable energy in Scotland we highlighted our concerns and sought Executive action.

The key points arising from these papers and based on the experience of our member organisations are listed below:

1. A Scottish Energy Strategy
The Executive should consult on and prepare a Scottish Energy Strategy;

• to co-ordinate and drive forward action on demand reduction and energy efficiency,
• to maximise the opportunities for renewable energy and
• to prevent ad hoc development in areas that require protection.

It should encourage a shift away from polluting technologies (coal, oil & gas, nuclear) to a combination of energy efficiency (with targets), reduced consumption (with targets) and renewable energy generation from a wide range of sources and technologies.

The Scottish Energy Strategy should encourage local energy generation and supply. The Strategy should clearly relate to other government strategies which should seek to reduce overall energy consumption, in particular, transport and waste. All Scottish Executive Departments and Agencies should contribute to the Strategy by, at a minimum, ensuring that their own frameworks and plans consider energy issues.

2. Targets
The Scottish Executive has taken a clear lead in endorsing renewables, and has set good targets for electricity from renewable sources - 40% of electricity production to come from renewables by 2020. This is a great start. These need to be complemented by targets for demand reduction and efficiency improvements.

3. Nuclear
The Scottish Executive should continue to resist the construction of any new nuclear capacity in Scotland, instead ensuring national investment in energy efficiency and expansion of appropriate renewable energy generation.

4. Planning and location
Scotland's National Planning Framework should address the implications of an ambitious and wide-ranging energy strategy. The Strategic Environmental Assessment Regulations and forthcoming Bill should be applied to energy policy. We support the development of combined oil & gas and offshore renewables strategic environment assessments provided the strategic areas chosen are based on the ecosystem approach and look forward to working with the Scottish Executive and DTI to ensure that these are well informed and comprehensive.

We welcome the Executive announcement that SEA of the Scottish coastline will be carried out in order to help investors identify potential offshore sites for wave and tidal power developments. Greater clarity regarding the policy framework for decision-making in the marine environment for all types of renewable energy would also be welcome.

Onshore wind energy schemes are currently meeting virtually all of Scotland's renewables targets, which other technologies can increasingly contribute to in the future. The scale of onshore wind development needs to be planned for now. LINK members endorse the need for a national, locational framework and the crucial role which national guidance will play. The locational work carried out by Scottish Natural Heritage is a welcome start but there is further work urgently required by other parts of Government. Meanwhile, sites where current carbon-storage capacity would be compromised by development should be avoided.

5. Protecting the wild land resource
Scotland has a much treasured and finite resource of wild land and seascape. Wildness in Scotland's countryside, islands and seascape is a quality that is valued by Scots and by people from all over the world, not only in the remotest parts of Scotland but also in more managed countryside, and it is a key resource of Scotland's tourist industry. The quality of wildness is particularly vulnerable to some forms of energy generation, such as wind turbines on high ridges, hydro schemes in remote areas, and offshore wind turbines or other marine technologies close to the shore. A Scottish Energy Strategy must protect wild land qualities in Scotland's countryside as well as the small declining reserve of remote wild land and sea passages.

6. National Grid (Transmission, Distribution and Connection)
The Executive should consider and consult widely on the needs and implications of an upgrade of the Scottish electricity grid. The current approach to transmission upgrades is entirely demand led and the subject of considerable conflict. SEA could be utilised to establish a robust and transparent approach to transmission and distribution.

Separate consideration of developments and grid connections should also be ended, enabling decision-makers to evaluate the total impacts of one proposal rather than evaluating them separately.

7. Baseline Data
To meet energy objectives, to plan appropriately and for regular comprehensive monitoring, Scotland will need accurate data on energy production and consumption.

8. Research and Development
An ambitious Scottish Energy Strategy will need commitment of substantial monies for research into new and developing technologies, and into potential implications of their application in Scotland. This programme should be imaginative and wide-ranging, including options such as geothermal imports, tidal flow, wave, offshore wind, biofuels, solar, and should include innovative transport, heating and energy saving technologies.

Effective monitoring and research is required in order to fully understand the impacts of individual developments and improve decision-making.

9. Stakeholders
Development of the strategy will need full and genuine consultation with all stakeholders. Stakeholders, including communities, should be consulted about all plans, policies and schemes. There should be maximum community ownership of, and community benefit from, any schemes.

We welcome the creation of EAFRE but are concerned that this Forum has no formal relationship with the Forum for Renewable Energy Development in Scotland (FREDS). These remit of these forums clearly overlap and a formal relationship must be established.

10. The Economy
The Enterprise Network should be required to develop policies and plans to realise the employment potential of the Scottish Energy Strategy.

11. The Scotland Act
It will be important to Scotland in the future to be able to adapt and develop its Energy Strategy to meet its needs and responsibilities. With energy issues divided between Westminster and Holyrood, it is important that these two administrations work together to the same aims, determined by the Scottish Energy Strategy. If it proves necessary to improve delivery, lead responsibility for one issue or another could be transferred.

12. Peat
Under the EU Habitats directive the Scottish Executive has a legal obligation towards the protection of peatland habitats which extends beyond those areas which have been designated as N2K sites. Whilst there is clear forestry policy to protect such habitat from tree planting, there is no equivalent policy in relation to devleopment planning and in particular renewable energy developments.

13. Biomass
In order to deliver a sustainable biomass energy policy, which delivers carbon savings, the planning of biomas developments should be coordinated with forestry policy. This should be done to ensure appropriate location and type of processing facilities to minimise haulage distances and road improvements as well as to facilitate local fuel provision for district heating systems.

Anne McCall, January 2004
LINK Planning Task Force Convenor

Review of the Scottish Climate Change Programme

Submission from Scottish Environment LINK
March 2005

Scottish Environment LINK (LINK) is the liaison body for Scotland's voluntary sector environmental organisations. LINK was established in 1987 to provide a forum and network for the voluntary environmental sector and to assist in co-operation and communication with government bodies and others with a role in Scotland's environment.

LINK members view climate change as the most serious problem facing the globe. There is clear evidence that the impacts of climate change are already being experienced and that they will get worse. Urgent action is required to reduce the anthropogenic greenhouse gas emissions that cause climate change if we are to avoid the worst consequences. We support a review of the Scottish Climate Change Programme in light of recent government figures which reveal that Scotland has made only limited progress on its emissions reductions. Individual members of LINK have made detailed comments on the Scottish Executive's consultation document. The following comments are intended to provide a generic overview of the issues and are supported by the organisations listed below.

Delivering Emissions Reductions

Questions 1-6
Scotland needs Scottish greenhouse gas targets and a realistic programme to achieve them.
Everyone - businesses small and large, the public, farmers, local councils - need to know what is expected of them and how they can do their bit to meet international targets. In the light of recent performance we think that Scotland should aim for a 12.5% reduction in greenhouse gas emissions on 1990 levels by 2010, and for a 60% cut in CO2 by 2050. And, importantly, Scotland needs to make year-on-year progress in all sectors towards these targets reporting regularly on progress to Parliament.

Questions 13-21
Scotland needs energy efficiency targets for domestic, commercial and industrial buildings, land use and food production.
Every year thousands of Scots die from conditions related to cold, damp housing. Solving this national disgrace is now a priority for Scotland and doing it right will also reduce the 25% of CO2 emissions which come from people's homes. Between 1990 and 2002 CO2 emissions from the Commercial sector rose by 35%, mainly because of increasing energy use within buildings. Energy use in the production of fertilizers, management of soil for agriculture and food production and procurement requires urgent review.

LINK supports the proposal for developing a Scottish Energy Efficiency Strategy. The Strategy needs to urgently prioritise action on demand reduction including the carrot of investment and incentive packages, but also to look at the stick of regulatory and financial measures.

The Scottish Executive should promote a wide range of renewable energy schemes within a Scottish Energy Strategy (LINK's Energy Statement refers to this issue).
Renewable energy sources, like energy from the wind, waves, sun and specially grown 'energy crops,' are essential in reducing emissions. There should be significantly improved planning and funding within the framework of a national energy strategy which brings on all the renewables, including those which produce heat, boost Combined Heat and Power schemes and work to phase out fossil fuels and nuclear power. Nuclear power is expensive and has major dangerous waste implications, Scotland's future energy provision, does not require new nuclear reactors. Investment in research, development and deployment of renewables is investment in clean energy, jobs in Scotland and new manufacturing industries. We think a challenging but achievable target for Scotland would be 50% of Scottish electricity to come from renewables by 2020.

Questions 28-31
Transport emissions are significant and growing; an effective integrated transport policy is required to curb these emissions.
Transport, mainly road transport, was responsible for 14% of climate change emissions in 2002 (excluding emissions from land use), and is the fastest growing sector of emissions. Aviation is the fastest growing source of traffic emissions with road traffic next. UK policy aims to cut transport emissions by 17% by 2010, half that reduction coming from measures like congestion charges and parking charges at work. More needs to be done to ensure that all transport proposals and policies contribute to reducing emissions, including an end to major, traffic-generating road schemes and measures to stabilise the growth in air travel.

Questions 32-50
The Government needs to help people to understand the consequences of the choices they make and to enable them to make climate-friendly choices.
The Government, industry and citizens all need to do their bit to tackle climate emissions, We can all help to reduce climate change emissions at work, at home, in school, etc, by making the right choices. Government should help us to do this by making the right choice the easy choice. This means investing in integrated transport, public information campaigns and leading the way by, for instance, forcing all new public buildings to meet tough efficiency standards and make use of renewables and/or CHP. Industry, business and commerce must be more robustly encouraged to lead by example.

Scotland must safeguard its carbon reservoirs, particularly peatlands, through improved management of the land.
Scotland's soils lock up a huge amount of carbon, far more than all the trees and shrubs in the UK put together, so it is vital to make sure these carbon 'stores' are protected through appropriate agricultural policies, an end to large-scale peat extraction and an urgent programme of peatland restoration. These policies would also protect the important wildlife and archaeological value of peat bogs and peat soils and contribute to a wider and integrated programme of land and landscape management. More generally, the choices we make about forestry, agriculture and built development should be designed to protect and enhance carbon locked in soils and vegetation, and to reduce direct carbon emissions.

Questions 51-54
Scotland's rural, urban, marine and coastal areas are going to be affected by climate change. We must accept this, minimising effects where possible and coming up with strategies which help us adapt.
The need to adapt has become ever more apparent since the publication of the Scottish Climate Change Programme in 2000. In the 2000 strategy, the section which addressed 'Adapting to the Impacts of Climate Change in Scotland' only formed a very small part of a much wider strategy. However, new scenarios on the likely scale of climate change are now more alarming and since it is now accepted that some degree of climate change is going to take place the adaptation strategy must be given a more prominent role in the revised strategy. As the consultation document notes: "some climate change is now inevitable and therefore it is vital that we adapt to the unavoidable impacts of climate change. These impacts will be felt increasingly on the environment, on communities and on business". The new strategy will need to address, amongst other, the threats posed by flooding, coastal realignment, changing farming practices and habitat fragmentation. We need to prepare today for the changes which will happen in the coming decades.

Adaptation to the reality of climate change can drive policy on the environment whilst, at the same time, safeguarding economic prosperity. As the report, Potential Adaptation Strategies for Climate Change in Scotland notes: 'The development of measures to adapt to climate change can help in re-thinking organisational goals and values, and in re-organising and re-engineering the provision of goods and services to customers and users'.

A more co-ordinated vision of land use is essential in formulating an adaptation strategy. It is therefore vital that the revised Scottish Climate Change Programme takes into account actions from the Scottish Biodiversity Strategy, the Scottish Sustainable Development Strategy, the implementation of the Water Framework Directive and the land use planning system.

We welcome the recognition in the Scottish Biodiversity Strategy of the need to increase the connections between areas of habitat. An integrated approach to the revision of the Scottish Climate Change Programme should inform an expanded adaptation section which focuses on the need to allow for spatial movement of species in response to climate change and restore the land to ecological functionality. Where possible, measures must be implemented that prevent adverse effects, such as the loss of important species, habitats and archaeological sites.

Landscape scale action should be pursued, facilitated by protection of all semi-natural habitats, restoring and creating new habitats, a more co-ordinated vision of land use to make it more permeable to species movement and allowing the recovery of the marine environment. As well as being good conservation practice, this approach can deliver economic and social gains such as flood alleviation, recreation and tourism and increased air and water quality. These aims could be delivered through a variety of agricultural, marine and land use mechanisms. It is important that measures, such as those aimed at tackling flooding, use as a first line of response sustainable flood management and soft-engineering techniques, and do not rely on building ever higher concrete flood defences An adaptive strategy for biodiversity would protect, restore and expand existing important habitat, and make the wider countryside more wildlife friendly to allow species and habitat movement.

Questions 55-59
Sustainable development means considering the environment, social issues and the economy together. Only by doing this can we really tackle climate change.
Climate change needs to be a major consideration in all areas of Government decision making and processes. Currently a number of competing priorities prevent a proper, joined-up response to climate change. The key example is the drive for economic growth. If the quality of the economy, rather than simply its size, were measured, it would be clear that climate change should be a major factor in economic and business planning. Education for sustainable development is a key part of changing the way we look at problems and make decisions. The emissions reduction and adaptation responses to climate change should be based on sustainability principles.

Scottish decision makers must play a part in international climate negotiations, pressing the UK, Europe and UN for action.
Scotland is part of the UK delegation to UN meetings on climate change. It is vital that Scottish interests are properly represented and that Scotland makes its full contribution to meeting UK targets. Scotland should help to ensure that international rules force most savings to be made 'at home', and that nuclear power and destructive forestry projects are not supported. It is essential that the UK keeps faith with the UN climate change process which respects the principle of climate justice for developing countries, rather than encouraging any side deals with the US.

Members of Scottish Environment LINK supporting this consultation response:

Badenoch and Strathspey Conservation Group
Biological Recording in Scotland
British Trust for Conservation Volunteers
Butterfly Conservation Scotland
Cairngorms Campaign
Council for Scottish Archaeology
Friends of the Earth Scotland
Hebridean Whale and Dolphin Trust
Marine Conservation Society Scotland
North East Mountain Trust
Plantlife Scotland
Rambers' Association Scotland
Royal Society for the Protection of Birds
Royal Zoological Society of Scotland
Scottish Council for National Parks
Scottish Native Woods
Scottish Wildlife Trust
Soil Association Scotland
Sustrans Scotland
The National Trust for Scotland
Whale and Dolphin Conservation Society
Woodland Trust Scotland
WWF Scotland

DEFRA consultation on the review of the UK Climate Change Programme

Submission by Scottish Environment LINK
March 2005

Scottish Environment LINK (LINK) is the liaison body for Scotland's voluntary sector environmental organisations. LINK was established in 1987 to provide a forum and network for the voluntary environmental sector and to assist in co-operation and communication with government bodies and others with a role in Scotland's environment.

LINK members view climate change as the most serious problem facing the globe. There is clear evidence that the impacts of climate change are already being experienced and that they will get worse. Urgent action is required to reduce the anthropogenic greenhouse gas emissions that cause climate change if we are to avoid the worst consequences.

The UK government and devolved administrations are rightly taking a lead in aiming to exceed the Kyoto targets for emissions reduction. Although progress has been made, it has been limited and the UK is unlikely to meet its target of 20% emissions reduction from 1990 base levels by 2010, under the current climate change Programme.

Scottish Environment LINK has submitted comments on the Scottish Executive's Climate Change programme and since many of the key policy areas are reserved matters we welcome the opportunity to provide the following comments on the UK programme. The organisations supporting this submission are listed below.

1) Improved Policy Delivery and Coordination
At the moment there is no mechanism to bring together key stakeholders at a UK level to work together on climate change.
The Government should establish a high level task force to bring stakeholders together to assist in developing climate change policies and monitor their delivery. Devolved administrations would need to play a key role.

2) Emissions Targets
We urge the UK government to continue to work towards firm UK emissions reduction targets from the 1990 baseline year for 2010 and 2050. We would also recommend setting annual improvement targets in emissions across all key sectors to stimulate year on year progress. Targets should be based on actual emissions reductions from a baseline rather than being compared against projections, which can be unreliable. It is also important that the government targets focus on emissions (ie the real outcome) rather than simply using other measures such as progress on renewables, which may not equate to emissions reduction.

3) Energy Saving
Urgent priority should be given to energy efficiency and demand management as this offers the largest, cheapest and least damaging opportunity for significant carbon emission reductions. The UK Government should introduce domestic and commercial energy reduction targets to achieve at least a 40% improvement by 2020. Scotland can move forward with its own energy efficiency targets and strategy, but Scottish targets would need to blend with UK targets. Only partnership working with the UK Government - enabled by fiscal and other reserved responsibilities - will ensure progress to the 2010 emissions reduction target.

4) Combined Heat and Power
The UK Government has set targets on Combined Heat and Power but has not provided any single, dedicated instrument for delivering it. We would encourage the early introduction of such an instrument with sufficient resourcing to support delivery of the CHP target. In addition the UK Government should lead by example in requiring all new major buildings built by or for the public sector to include CHP and/or renewable energy sources. This would lead to major reductions in emissions, set an example for the private sector as well as create jobs and new industries in the UK.

5) Research and development investment in the full range of renewable energy technologies
To reduce our climate change emissions the UK must invest in all forms of renewable energy, to make electricity, fuels and direct heat. As a result of the Government's design of the Renewables Obligation which supports only near market technologies most effort has gone on electricity from on-shore windfarms. We would like to see more financial support either through a banded Renewables Obligation or direct Government funding for research and development in other renewables.

6) Make the price of all transport journeys more fairly reflect their cost to the environment
Emissions from traffic are growing year on year, while most other emissions are falling. If no action is taken, transport could be the largest source of CO2 before 2015.

The UK Government, along with devolved administrations, need to take action on fiscal policies to ensure that transport pays for its external environmental and social impacts.
For example, Vehicle Excise Duty for large, polluting, 4x4s and Sports Utility Vehicles should be much higher than those for normal cars. The UK Government must also lead talks in Europe to make the price of flights properly reflect their growing contribution to climate change emissions.

7) Set tough emissions trading targets for power companies and industry
The power companies and other big industries are among our biggest producers of carbon dioxide. To deliver a cut of at least 20% by 2010, the UK Government must set tough limits for carbon dioxide emissions on power companies and other industry sectors covered by the new European Emissions Trading Scheme.

8) A sustainable approach to Mitigation and Adaptation
Climate change should be made a major consideration in all areas of Government decision making and processes. Currently a number of competing priorities prevent a proper, joined up response to climate change. A sustainable approach would seek ways of delivering climate change and other policy objectives for example through proper strategic planning to deliver renewables without causing environmental harm.

It is also important to ensure that adaptation to climate change is taken forward in a sustainable way, such as addressing flooding through catchment management, incorporating natural systems.

New scenarios on the likely scale of climate change are now more alarming and since it is now accepted that some degree of climate change is going to take place the adaptation must be given a more prominent role in the revised strategy. The new strategy will need to address, amongst other, the threats posed by flooding, coastal realignment, changing farming practices and habitat fragmentation. We need to prepare today for the changes which will happen in the coming decades. Adaptation to the reality of climate change can drive policy on the environment whilst, at the same time, safeguarding economic prosperity.

An integrated approach to the revision of the UK Climate Change Programme should inform an expanded adaptation section which focuses on the need to allow for spatial movement of species in response to climate change and restore the land to ecological functionality. Where possible, measures must be implemented that prevent adverse effects, such as the loss of important species, habitats and archaeological sites.

Landscape scale action should be pursued, facilitated by protection of all semi-natural habitats, restoring and creating new habitats, a more co-ordinated vision of land use to make it more permeable to species movement and allowing the recovery of the marine environment. As well as being good conservation practice, this approach can deliver economic and social gains such as flood alleviation, recreation and tourism and increased air and water quality. These aims could be delivered through a variety of agricultural, marine and land use mechanisms. It is important that measures, such as those aimed at tackling flooding, use as a first line of response sustainable flood management and soft-engineering techniques, and do not rely on building ever higher concrete flood defences An adaptive strategy for biodiversity would protect, restore and expand existing important habitat, and make the wider countryside more wildlife friendly to allow species and habitat movement.

Members of Scottish Environment LINK supporting this consultation response:

Badenoch and Strathspey Conservation Group
Biological Recording in Scotland
British Trust for Conservation Volunteers
Butterfly Conservation Scotland
Cairngorms Campaign
Council for Scottish Archaeology
Friends of the Earth Scotland
Hebridean Whale and Dolphin Trust
Marine Conservation Society Scotland
Mountaineering Council of Scotland
North East Mountain Trust
Plantlife Scotland
Rambers' Association Scotland
Royal Society for the Protection of Birds
Royal Zoological Society of Scotland
Scottish Council for National Parks
Scottish Native Woods
Scottish Wildlife Trust
Soil Association Scotland
Sustrans Scotland
The National Trust for Scotland
Whale and Dolphin Conservation Society
Woodland Trust Scotland
WWF Scotland

Written Evidence to the Environment and Rural Development Committee Inquiry on Climate Change

LINK Climate Change Action Plan

Scottish Environment LINK member bodies (listed below) believe that Scotland needs urgent action on climate change and highlight the following 10-points:

• Climate Change is happening already, it will get worse and urgent action is needed now to prevent the worst consequences
• Scotland needs Scottish greenhouse gas reduction targets and a realistic programme to achieve them
• Scotland's rural, urban, coastal and marine areas are going to continue to be seriously affected by climate change. We must accept this, mitigating effects where possible and coming up with strategies which help us adapt where not
• As part of a Scottish Energy Strategy, the Scottish Executive should take an active role in promoting a diverse base of renewable energy schemes
• Transport emissions are significant and growing; an effective integrated transport policy is required to curb these emissions
• Alongside increasing production from clean energy sources, Scotland needs to reduce consumption and must implement energy efficiency targets for domestic, commercial and industrial buildings
• Scotland must safeguard its carbon reservoirs, particularly peatlands
• Individuals can make a difference, but people need to understand the consequences of the choices they make about where they live, how they travel, what they buy etc.
• Scotland must play its part in international climate negotiations
• Only with sustainable development addressing the environment, social issues and the economy together, can we really tackle climate change.

LINK member bodies are keen to contribute to taking these actions in Scotland.

CLIMATE CHANGE

Climate change is the most serious environmental problem facing the globe. In Scotland it will mean more unpredictable weather, more storms and rising seas, leading to floods, drought, failed harvests, the spread of disease and whole species being wiped out.

The UK signed up to climate targets at the Earth Summit in Rio in 1992 and further targets at Kyoto in 1997. The Scottish Executive has pledged that we will 'play our part' and 'make an equitable contribution' to meeting these targets but the Scottish Climate Change Programme did not set any specific targets for Scotland and specifies little actual action.

In Scotland we are already falling behind in tackling climate change. Recent Government figures reveal that Scotland's emissions of CO2 fell 5.6% between 1990 and 2002, while overall UK reduction was 15%.

Taking action on climate change will have extra benefits - as well as avoiding the worst damage from the changing weather and addressing problems already being faced in farming and fisheries, Scotland will create jobs, and reduce air pollution and related health problems.

In more detail:

Climate Change is happening already, it will get worse and urgent action is needed now to prevent the worst consequences.
From the weather disasters around the world to breeding times of birds, there is no question that things are changing, with 7 of the 10 hottest years since 1961 occurring in the last decade. The more we do today to reduce emissions the less damage will happen in the future and the cheaper it will be to cope with change.

Scotland needs Scottish greenhouse gas targets and a realistic programme to achieve them.
Clear national and sectoral targets are needed so that everyone - business people, farmers, the public, councils - know what is expected of them and how they can do their bit to meet international targets. In the light of recent performance we think that Scotland should aim for a 20% reduction in CO2 emissions on 1990 levels by 2010. We further support the Royal Commission on Environmental Pollution's call for a cut of 60% by 2050.

Scotland's rural, urban, marine and coastal areas are going to be affected by climate change. We must accept this, mitigating effects where possible and coming up with strategies which help us adapt where not.
From coping with flooding to realigning the coast and from changing farming to retraining doctors, we need to prepare today for the changes which will happen in the coming decades. Where possible, measures must be implemented that mitigate for adverse effects, such as the loss of important species, habitats and archaeological sites. We need to turn problems into opportunities where we can but also recognise that there will be real costs to pay.

The Scottish Executive should take a more active role in promoting a wide range of renewable energy schemes.
Renewable energy sources, like energy from the wind, waves, sun and specially grown 'energy crops,' are essential if we are to use less fossil fuels and phase out nuclear power. Investment in renewables is investment in clean energy, jobs in Scotland and new manufacturing industries. We think a challenging but achievable target for Scotland would be 25% of Scottish electricity to come from renewables by 2010 and 50% by 2025. There should be significantly improved planning and funding within the framework of a national energy strategy. Incinerating municipal waste does not produce renewable energy and should not be included as a renewable.

Transport emissions are significant and growing; an effective integrated transport policy is required to curb these emissions.
Transport, mainly road transport, was responsible for 14% of climate change emissions in 2002, and is the fastest growing sector of emissions. Road traffic is the second fastest growing source of greenhouse gas emissions with aviation the fastest. UK policy aims to cut transport emissions by 17% by 2010, half that reduction coming from measures like charges to come into cities and parking charges at work. Current action is not sufficient to produce the reductions needed. All transport policies and projects should be assessed against their climate change impact.

Scotland needs energy efficiency targets for domestic, commercial and industrial buildings.
Every year thousands of Scots die from conditions related to cold, damp housing. Solving this national disgrace should be an urgent priority and doing it right will also reduce the 22% of CO2 emissions which come from people's homes. Between 1990 and 2002 CO2 emissions from the Commercial sector rose by 35%, mainly because of increasing energy use within buildings.

Scotland must safeguard its carbon reservoirs, particularly peatlands.
Scotland's soils lock up a huge amount of carbon, far more than all the trees and shrubs in the UK put together, so it is vital to make sure these carbon 'sinks' are protected through appropriate agricultural policies, an end to large-scale peat extraction and an urgent programme of peatland restoration. These policies would also conserve biodiversity and archaeological value of peat bogs.

Individuals can make a difference, but people need to understand the consequences of the choices they make about where they live, how they travel, what they buy etc.
We can all help to reduce climate change emissions at work, at home, in school etc by making the right choices. The Government should help people to do this through good planning advice, integrated transport and public information campaigns.

Scotland must play its part in international climate negotiations.
Scotland is part of the UK delegation to UN meetings on climate change. It is vital that Scottish interests are properly represented and that Scotland makes a full contribution to meeting UK targets. Scotland should help to ensure that international rules force most savings to be made 'at home', and that nuclear power and destructive forestry projects are not supported.

Sustainable development means considering the environment, social issues and the economy together. Only by doing this can we really tackle climate change.
Climate change needs to be a major consideration in all areas of Government decision making and processes. Education for sustainable development is a key part of changing the way we look at problems and make decisions. The mitigation and adaptation response to climate change should also be sustainable.

Scottish Environment LINK member bodies have called on the Scottish Executive to develop, implement and resource a detailed Scottish Strategy on Climate Change which addresses these points and brings together social, environmental and economic interests to reduce emissions and improve quality of life.

Notes

Scottish Environment LINK is the liaison body for Scotland's voluntary sector environmental organisations. LINK was established in 1987 to provide a forum and network for the voluntary environmental sector to assist in co-operation and communication with government bodies and other bodies with a role in Scotland's environment. There are currently 36 member bodies in LINK, representing around half a million people.

This statement is supported by the following LINK bodies :

ruralScotland
Association of Regional and Island Archaeologists
Badenoch and Strathspey Conservation Group
Biological Recording in Scotland Campaign
Butterfly Conservation
BTCV Scotland
Cairngorms Campaign
Council for Scottish Archaeology
Friends of the Earth Scotland
Friends of Loch Lomond
Hebridean Whale and Dolphin Trust
John Muir Trust
Marine Conservation Society

North East Mountain Trust

Plantlife Scotland
Ramblers' Association Scotland
Reforesting Scotland
Royal Society for the Protection of Birds Scotland
Saltire Society
Scottish Council for National Parks
Scottish Native Woods
Scottish Wild Land Group
Scottish Wildlife Trust
Sustrans Scotland

February 2005

Energy in Scotland

LINK written evidence to the The Enterprise and Culture Committee's Inquiry into Renewables, January 2004

Introduction

Climate change is already bringing very unpredictable weather affecting thousands of householders, businesses and many parts of the country’s infrastructure. We must act now to slow the rate at which climate change is happening to mitigate negative impacts both on human society and on ecosystems. Action will bring benefits: as well as reducing these impacts it will create new, ‘green’ jobs, and help to reduce air pollution and related health problems.

The 2002 UK Energy Review by the Performance and Innovation Unit (PIU) indicates real potential for the UK to move to a low carbon energy system as part of the drive for continued carbon emissions reductions. The review shows that this can be reached through a combination of energy efficiency, renewable energy and combined heat and power. The UK and Scottish Governments should commit to driving the development of demand reduction and energy efficiency measures alongside clean technologies to reflect the potential identified by the PIU. This would avoid the need to rely on environmentally unacceptable technologies such as nuclear and would limit the damaging impacts of energy infrastructure on the wider environment.

However, Scotland can do much more to meet the climate challenge. Members of Scottish Environment LINK [1] propose a number of measures below.

1. A Scottish Energy Strategy

The Executive should consult on and prepare a Scottish Energy Strategy;

• to co-ordinate and drive forward action on demand reduction and energy efficiency
• to maximise the opportunities for renewable energy
• to prevent ad hoc development in areas that require protection.

It should encourage a shift away from polluting technologies (coal, oil & gas, nuclear) to a combination of energy efficiency (with targets), reduced consumption (with targets) and renewable energy generation from a wide range of sources and technologies.
The Scottish Energy Strategy should encourage local energy generation and supply. The Strategy should clearly relate to other government strategies which should seek to reduce overall energy consumption, in particular transport and waste. All Scottish Executive Departments and Agencies should contribute to the Strategy by, at a minimum, ensuring that their own frameworks and plans consider energy issues.

2. Targets

The Scottish Executive has taken a clear lead in endorsing renewables, and has set good targets for electricity from renewable sources - 40% of electricity production to come from renewables by 2020. This is a great start. These need to be complemented by targets for demand reduction and efficiency improvements.

3. Nuclear

The Scottish Executive should continue to resist the construction of any new nuclear capacity in Scotland, instead ensuring national investment in energy efficiency and expansion of appropriate renewable energy generation.

4. Planning and location

Scotland's National Planning Framework should address the implications of an ambitious and wide-ranging energy strategy. The Strategic Environmental Assessment Directive to come into force in the UK by summer 2004 should be applied to energy policy. We support the development of combined oil & gas and offshore renewables strategic environment assessments provided the strategic areas chosen are based on the ecosystem approach and look forward to working with the Scottish Executive and DTI to ensure that these are well informed and comprehensive.
Onshore wind energy schemes are currently meeting virtually all of Scotland's renewables targets which other technologies can increasingly contribute to in the future. The scale of onshore wind development needs to be planned for now. LINK members endorse the need for a national, locational framework and the crucial role which national guidance will play. The locational work carried out by Scottish Natural Heritage [2] is a welcome start but there is further work urgently required by other parts of Government. Meanwhile, sites where current carbon-storage capacity would be compromised by development should be avoided.

5. Protecting the wild land resource

Scotland has a much treasured and finite resource of wild land and seascape. [3] NPPG6 deals poorly with the issue of wild landscapes. Wildness in Scotland's countryside, islands and seascape is a quality that is valued by Scots and by people from all over the world, not only in the remotest parts of Scotland but also in more managed countryside, and it is a key resource of Scotland's tourist industry. The quality of wildness is particularly vulnerable to some forms of energy generation, such as wind turbines on high ridges, hydro schemes in remote areas, and offshore wind turbines or other marine technologies close to the shore. A Scottish Energy Strategy must protect wild land qualities in Scotland's countryside as well as the small declining reserve of remote wild land and sea passages.

6. National Grid

The Executive should consider and consult widely on the needs and implications of an upgrade of the Scottish electricity grid.

7. Baseline Data

To meet energy objectives, to plan appropriately and for regular comprehensive monitoring, Scotland will need accurate data on energy production and consumption.

8. Research and Development

An ambitious Scottish Energy Strategy will need commitment of substantial monies for research into new and developing technologies, and into potential implications of their application in Scotland. This programme should be imaginative and wide-ranging, including options such as geothermal imports, tidal flow, wave, offshore wind, biofuels, solar, and should include innovative transport, heating and energy saving technologies.

9. Stakeholders

Development of the strategy will need full and genuine consultation with all stakeholders. Stakeholders, including communities, should be consulted about all plans, policies and schemes. There should be maximum community ownership of, and community benefit from, any schemes.

10. The Economy

The Enterprise Network should be required to develop policies and plans to realise the employment potential of the Scottish Energy Strategy.

11. The Scotland Act

It will be important to Scotland in the future to be able to adapt and develop its Energy Strategy to meet its needs and responsibilities. With energy issues divided between Westminster and Holyrood, it is important that these two administrations work together to the same aims, determined by the Scottish Energy Strategy. If it proves necessary to improve delivery, lead responsibility for one issue or another could be transferred.
The following LINK member organisations are signatories to this statement:

• Association of Regional and Islands Archaeologists
• Biological Recording in Scotland Campaign
• Badenoch and Strathspey Conservation Group
• British Association of Nature Conservationists (Scotland)
• Cairngorms Campaign
• Friends of the Earth Scotland
• Marine Conservation Society
• Mountaineering Council of Scotland
• The National Trust for Scotland
• Ramblers Association Scotland
• RSPB Scotland
• Scottish Wild Land Group
• Sustrans Scotland
• The Woodland Trust Scotland
• WWF Scotland

Reference List
Performance and Innovation Unit Energy Review 2002 www.cabinet-office.gov.uk/innovation/2002/energy/report/index.htm
Scottish Executive Securing a Renewable Future: Scotland's Renewable Energy http://www.scotland.gov.uk/library5/environment/srfe-00.asp
DTI Energy White Paper Our Energy Future - Creating a low carbon economy, 2003 http://www.dti.gov.uk/energy/whitepaper/index.shtml#wp
DTI Offshore Wind SEA 2003 see http://www.dti.gov.uk/energy/renewables/technologies/offshore_wind.shtml
NPPG6 Renewable Energy Developments 2000, http://www.scotland.gov.uk/library3/planning/nppg/nppg6-00.asp
A Smart Sustainable Scotland, the potential for green enterprise and green jobs prepared for WWF Scotland by CAG Consultants, 2003. http://www.wwf.org.uk/filelibrary/pdf/smartscotland.pdf
Scottish Natural Heritage Policy Statement: Wildness in Scotland's Countryside http://www.snh.org.uk/strategy/sr-frame.htm
Scottish Natural Heritage Strategic Locational Guidance for onshore wind farms in respect of the natural heritage, 2002. http://www.snh.org.uk/strategy/sr-frame.htm

Further information:
Scottish Environment LINK
LINK Parliamentary Office
PO Box 23137
Edinburgh
EH1 2NX
Email: jessica@scotlink.org
Web: www.scotlink.org
All the above LINK member organisations contact details are available on http://www.scotlink.org/mem.htm

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LINK Energy Statement, July 2003

Introduction

Climate change is already bringing very unpredictable weather affecting thousands of householders, businesses and many parts of the country’s infrastructure. We must act now to slow the rate at which climate change is happening to mitigate negative impacts both on human society and on ecosystems. Action will bring benefits: as well as reducing these impacts it will create new, ‘green’ jobs, and help to reduce air pollution and related health problems.

The 2002 UK Energy Review by the Performance and Innovation Unit (PIU) indicates real potential for the UK to move to a low carbon energy system as part of the drive for continued carbon emissions reductions. The review shows that this can be reached through a combination of energy efficiency, renewable energy and combined heat and power. The UK and Scottish Governments should commit to driving the development of demand reduction and energy efficiency measures alongside clean technologies to reflect the potential identified by the PIU. This would avoid the need to rely on environmentally unacceptable technologies such as nuclear and would limit the damaging impacts of energy infrastructure on the wider environment.

However, Scotland can do much more to meet the climate challenge. Members of Scottish Environment LINK [1] propose a number of measures below.

1. A Scottish Energy Strategy

The Executive should consult on and prepare a Scottish Energy Strategy, to co-ordinate and drive forward action on demand reduction and energy efficiency, to maximise the opportunities for renewable energy and to prevent ad hoc development in areas that require protection. It should encourage a shift away from polluting technologies (coal, oil & gas, nuclear) to a combination of energy efficiency (with targets), reduced consumption (with targets) and renewable energy generation from a wide range of sources and technologies. The Scottish Energy Strategy should encourage local energy generation and supply. The Strategy should clearly relate to other government strategies which should seek to reduce overall energy consumption, in particular transport and waste. All Scottish Executive Departments and Agencies should contribute to the Strategy by, at a minimum, ensuring that their own frameworks and plans consider energy issues.

2. Targets: The Scottish Executive has taken a clear lead in endorsing renewables, and has set good targets for electricity from renewable sources - 40% of electricity production to come from renewables by 2020. This is a great start. These need to be complemented by targets for demand reduction and efficiency improvements.

3. Nuclear

The Scottish Executive should continue to resist the construction of any new nuclear capacity in Scotland, instead ensuring national investment in energy efficiency and expansion of appropriate renewable energy generation.

4. Planning and location

Scotland’s National Planning Framework should address the implications of an ambitious and wide-ranging energy strategy. The Strategic Environmental Assessment Directive to come into force in the UK by summer 2004 should be applied to energy policy. We support the development of combined oil & gas and offshore renewables strategic environment assessments provided the strategic areas chosen are based on the ecosystem approach and look forward to working with the Scottish Executive and DTI to ensure that these are well informed and comprehensive.

Onshore wind energy schemes are currently meeting virtually all of Scotland’s renewables targets which other technologies can increasingly contribute to in the future. The scale of onshore wind development needs to be planned for now. LINK members endorse the need for a national, locational framework and the crucial role which national guidance will play. The locational work carried out by Scottish Natural Heritage [2] is a welcome start but there is further work urgently required by other parts of Government. Meanwhile, sites where current carbon-storage capacity would be compromised by development should be avoided.

5. Protecting the wild land resource

Scotland has a much treasured and finite resource of wild land and seascape. [3] NPPG6 deals poorly with the issue of wild landscapes. Wildness in Scotland’s countryside, islands and seascape is a quality that is valued by Scots and by people from all over the world, not only in the remotest parts of Scotland but also in more managed countryside, and it is a key resource of Scotland's tourist industry. The quality of wildness is particularly vulnerable to some forms of energy generation, such as wind turbines on high ridges, hydro schemes in remote areas, and offshore wind turbines or other marine technologies close to the shore. A Scottish Energy Strategy must protect wild land qualities in Scotland’s countryside as well as the small declining reserve of remote wild land and sea passages.

6. National Grid

The Executive should consider and consult widely on the needs and implications of an upgrade of the Scottish electricity grid.

7. Baseline Data

To meet energy objectives, to plan appropriately and for regular comprehensive monitoring, Scotland will need accurate data on energy production and consumption.

8. Research and Development

An ambitious Scottish Energy Strategy will need commitment of substantial monies for research into new and developing technologies, and into potential implications of their application in Scotland. This programme should be imaginative and wide-ranging, including options such as geothermal imports, tidal flow, wave, offshore wind, biofuels, solar, and should include innovative transport, heating and energy saving technologies.

9. Stakeholders

Development of the strategy will need full and genuine consultation with all stakeholders. Stakeholders, including communities, should be consulted about all plans, policies and schemes. There should be maximum community ownership of, and community benefit from, any schemes.

10. The Economy

The Enterprise Network should be required to develop policies and plans to realise the employment potential of the Scottish Energy Strategy.

11. The Scotland Act

It will be important to Scotland in the future to be able to adapt and develop its Energy Strategy to meet its needs and responsibilities. With energy issues divided between Westminster and Holyrood, it is important that these two administrations work together to the same aims, determined by the Scottish Energy Strategy. If it proves necessary to improve delivery, lead responsibility for one issue or another could be transferred.

The following LINK member organisations are signatories to this statement:

• Association of Regional and Islands Archaeologists
• Biological Recording in Scotland Campaign
• Badenoch and Stratspey Conservation Group
• British Association of Nature Conservationists (Scotland)
• Cairngorms Campaign
• Friends of the Earth Scotland
• Marine Conservation Society
• Mountaineering Council of Scotland
• The National Trust for Scotland
• Ramblers Association Scotland
• RSPB Scotland
• Scottish Wild Land Group
• Sustrans Scotland
• The Woodland Trust Scotland
• WWF Scotland

Reference List

Performance and Innovation Unit Energy Review 2002 www.cabinet-office.gov.uk/innovation/2002/energy/report/index.htm

Scottish Executive Securing a Renewable Future: Scotland’s Renewable Energy http://www.scotland.gov.uk/library5/environment/srfe-00.asp

DTI Energy White Paper Our Energy Future – Creating a low carbon economy, 2003 http://www.dti.gov.uk/energy/whitepaper/index.shtml#wp

DTI Offshore Wind SEA 2003 see http://www.dti.gov.uk/energy/renewables/technologies/offshore_wind.shtml

NPPG6 Renewable Energy Developments 2000, http://www.scotland.gov.uk/library3/planning/nppg/nppg6-00.asp

A Smart Sustainable Scotland, the potential for green enterprise and green jobs prepared for WWF Scotland by CAG Consultants, 2003. http://www.wwf.org.uk/filelibrary/pdf/smartscotland.pdf

Scottish Natural Heritage Policy Statement: Wildness in Scotland’s Countryside http://www.snh.org.uk/strategy/sr-frame.htm

Scottish Natural Heritage Strategic Locational Guidance for onshore wind farms in respect of the natural heritage, 2002. http://www.snh.org.uk/strategy/sr-frame.htm

Further information:

Scottish Environment LINK

2 Grosvenor House

Shore Road

Perth PH2 8BD

Web: www.scotlink.org

All the above LINK member organisations contact details are available on http://www.scotlink.org/mem.htm

.--------------------------------------------------------------------------------

[1] LINK is the liaison body for Scotland's voluntary sector environmental organisations which represent around half a million people.

[2] SNH Strategic locational guidance for onshore wind farms in respect of the natural heritage, 2002

[3] SNH Policy Statement Wildness in Scotland's Countryside 2002

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