The effects of the feed-in tariff on the development sector
Bernice Roberts and Pete Etheridge from The Landmark Practice reflect on the lessons to be learned from the treatment of biodiversity in the delivery of renewable energy developments.
In a world driven by market demand for swift and cost-effective delivery, all players within the development sector, including consenting authorities, need the early identification of potential project constraints and opportunities. Clarity of scope enables resources to be focused on those issues genuinely material to consideration of environmental effects.
The need for clarity is shown in sharp relief in the renewable energy sector. Launched in April 210, the UK feed-in tariff (FIT) was designed to increase renewable generation and caused a surge in interest in development of solar photovoltaic (PV) and small and medium-scale wind turbines.
Despite the collapse of the large-scale PV sector following the hefty reduction in FIT tariffs this year, and with further cuts possible, a number of applications for solar PV and wind schemes are still moving through the planning system. Uncertainty about government incentives adds tension to developers’ perennial dilemma of whether the risk of pushing forward with an application to meet operational deadlines outweighs the possibility that insufficient technical information will delay planning determination, or leave scope for challenge to any consent given.
Planning for biodiversity
Experienced developers know that ecology must be considered during the design phase of a project. The FIT has, however, brought many without that experience into the sector and it can be a shock for them to find that something as apparently simple as the timing of ecological surveys can significantly impact a project’s programme and viability.
Technical guidance from an ecologist at the earliest stage of project feasibility and site selection is as important as essential commercial considerations, such as grid capacity. Working collaboratively, the applicant, land agent, grid operator, planner, ecologist and local planning authority can reduce overall development risk by identifying ecological constraints and guiding the type and scale of development to the optimum location.
Some ecological issues are common to both solar PV and wind turbine schemes, while others are technology specific. For example, while the effect of solar PV installations is relatively neutral for most bats, wind turbines can cause significant mortality and disturbance to bat populations. The UK is home to 18 species of bat, all of which are protected under both UK and European legislation.
Bats often use linear features such as hedgerows, streams and woodland edges to travel between their roosts and foraging habitat. Natural England recommends a distance of 50m between the nearest point of a turbine blade and any linear feature, so siting wind turbines close to these features can necessitate the need for extensive bat survey work to establish whether they will be affected. The 2011 Bat Conservation Trust guidance on assessing the impacts of wind turbines on bats recommends that, for some sites, surveying should take place from April to October.
Given the commercial pressure to meet FIT deadlines, failure to scope properly, or to provide the correct information, could have serious consequences for the planning programme, potentially leading to an otherwise technically, financially and environmentally acceptable project being abandoned.
It’s possible that surveys can be completed more quickly, depending on the project design, but additional surveys may also prove an advantage if project details need to change later in the design phase. It is always safer to assume that ecological surveys, due to their seasonal requirements, could take one year to complete.
Delivery deadlines to achieve optimum FIT registration means that siting of solar PV or wind schemes in or close to potentially sensitive sites, such as those covered by legal and statutory designations (European sites, National Nature Reserves and Sites of Special Scientific Interest) and protected species legislation, is best avoided. In terms of the information needed to inform a planning application, and the time required to gather data, the bar is set higher for such sites than for non-designated areas.
Protected sites and development are not always incompatible, however, and ecologists can offer informed judgement, not only about whether the proposed project is likely to affect the qualifying features of a protected site, but also on how development can enhance the site and local biodiversity.
There are now many solar PV and wind schemes within areas of conservational interest, from locally designated sites to those immediately adjacent to internationally important sites. These projects demonstrate how an integrated approach to project planning can make an important contribution to both renewable energy targets and ecological enhancement.
Developers, consultants and planning authorities are subject to complementary pressures. Planning authorities are required to consider the impacts of developments on protected species and it’s the applicant’s responsibility to provide evidence enabling the authority to discharge its duties under the Habitat Regulations. The authority must be satisfied the development can be delivered without a significant effect on a protected species before it is permitted to grant planning consent.
Notwithstanding proposals to simplify the planning regime in England, the UK remains subject to European law, which requires any development consent to be informed by accurate and up-to-date environmental information.
In a challenging economic climate, it is more important than ever that all the players within the development sector are properly informed and work collaboratively to deliver development that meets environmental best practice.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice. To discuss the themes raised by the article with other environmental professionals visit IEMA’s LinkedIn group.
Bernice Roberts is a director and principal environmental planner at The Landmark Practice and has project managed numerous renewable energy development schemes and lectures on planning and energy development. Pete Etheridge is a senior ecologist at The Landmark Practice. He has extensive experience of renewable energy projects and has worked on some of the largest development in the country.