I completely agree with Liz Hamilton that the delivery plan is a good start. I can understand that the NPF4 has changed significantly between drafts and now the delivery plan has to do a bit of running to catch up. It is heading in the right direction, but it is not as developed as we want to see and again I would reiterate Liz’s point about the speed of implementation.
In terms of what we should monitor, the UK Climate Change Committee provides independent advice to the Scottish Government and Administrations across the UK on what is needed to get to net zero. As it is a framework that is supposed to enable the meeting of net zero, we want to see the NPF4 monitored against that goal. Again, we expect biodiversity targets to come through Parliament soon, and it should be measured against them.
I want to pick up on a couple of key things that, from a renewables perspective, we would like to be monitored—one has come up in conversation already, but one has not. The first one is around wild land. As it has been alluded to, there has been a change of policy around that. To be clear about what that means in practice, the policy now says that you can develop commercial wind farms and renewables on wild land. However, there are some big caveats to that, as 49 per cent of wild land sits within national parks or national scenic areas, which means that it could never be developed for renewables.
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Once you include everything that has a designation on it—sites of special scientific interest and so on—or things such as lochs or rivers, which are, obviously, not suitable for renewables, you are left with only about a third of the wild land in Scotland, and you must then get into issues such as whether the wind regime is sufficient or whether there is a grid connection and so on, so the amount of suitable wild land becomes smaller and smaller. That means that it is not simply the case that all wild land can be now considered as a site. What is the case is that around a third of it is now a possibility that could be explored. We need to ensure that that is coming through in policy.
There is one other thing that is a deep concern of ours around how the NPF4 has been written that will need to be monitored very closely, because we have identified a key conflict in the policies. Policy 11 identifies very clearly the need for grid reinforcements to our electricity grid if we are to be able to meet net zero. I should make it clear to the committee that how a grid works is a unique thing in planning. In Scotland, there are two grid operators: Scottish and Southern Electricity Networks in the north; and Scottish Power Energy Networks in the south. They are natural monopolies, so they are regulated very closely by the Office of Gas and Electricity Markets, and what they can and cannot build is regulated very closely. They must operate under two parameters. One is that they must provide people with connections to the grid, but that must be at the lowest cost to the consumer, and it must maintain the stability and integrity of our electricity system.
There is what is called the pathway to 2030, which has a clear plan of what grid connections will be needed as we move towards that date. SSEN Networks has highlighted that the majority of ancient woodland in Scotland sits within its area. It has produced a detailed map of the grid reinforcements that it will need to do, and it cannot find a way where it can do that without impinging in some places on ancient woodland.
Currently we have the policy in NPF4 policy 6(b), which states:
“Development proposals will not be supported where they will result in ... any loss of ancient woodlands, veteran trees, or adverse impact on their ecological condition”.
We absolutely support that policy, but we are going to hit up against the conflict that I outlined. I should make it clear that, as an organisation, SSEN Networks has a biodiversity net gain strategy and has committed that every project that it does will result in a gain for biodiversity.
An example of where the kind of conflict that I am talking about has come up is in Argyll—I will have to look up the specific name of that project, because there are many. It involved grid reinforcement work around the west coast, working with the Argyll and the Isles Coast and Countryside Trust. The grid reinforcement ran from Inveraray to Crossaig and impacted on Scotland’s Atlantic rainforest, which is a precious resource. SSEN could not avoid having an impact there, so it paid for a woodland officer, outdoor learning opportunities, the use of local supply chain and health and wellbeing improvements, and carried out mitigation planting, so the area of woodland was expanded beyond the area of impact. That is something that we are going to have to monitor closely, because, as I said, as an industry, we are absolutely committed to that biodiversity target and to the preservation of ancient woodland. However, to enable people to access electricity the necessary grid reinforcements are going to come in conflict with that commitment, at some point. That is something that we want the committee to pay close attention to, as if we had accidentally created the undermining of one policy by the other. I will stop there.