Background for members
The Landscape Institute have responded to Scottish Government’s consultation on the Draft Energy Strategy and Just Transition Plan for Scotland which outlines a route map of ambitions and actions in the move towards a net zero energy system, presenting the vision for Scotland’s future decarbonised energy system and the actions needed to deliver it. It sets a vision to 2045 and coupled with detailed sectoral plans and the forthcoming Climate Change Plan, will guide decision-making and policy support to 2030.The strategy outlines plans and policy positions for the transformation of energy generation, transportation, and use, including a strong focus on maximising the benefits of renewable energy resources. It sets out the scale of that opportunity and provides clarity on how Scotland will prepare for a Just Energy Transition for workers, businesses, communities, and regions. The aim is that the Strategy and Plan will provide policy certainty for consumers, businesses and investors and set a clear direction for the future of Scotland’s oil and gas sector.Many of the key decision-making powers in energy sit with the UK Government, with responsibility for making or changing legislation and regulations reserved under the Scotland Act. This strategy therefore also outlines areas that that Scottish Government have determined as being critical for the UK Government to act on to secure the full benefits of the energy transition for Scotland.Landscape Institute responseThis consultation is split into 6 chapters:
- Introduction and Vision
- Preparing for a Just Energy Transition
- Energy Supply
- Scaling up renewables
- North Sea oil and gas
- Energy Demand
- Heat in buildings
- Energy for transport
- Energy for agriculture
- Energy for industry
- Creating the Conditions for a Net Zero Energy System
- Route Map to 2045
- Impact assessment questions
- Just transition energy outcomes
We submitted a partial response to this consultation focusing on renewable energy, skills, and green jobs.
Summary
- We support the ambition of the vision and the commitment to addressing the energy and climate changes crises, while ensuring the preservation and restoration of biodiversity.
- A bold and multi-faceted approach will be required to achieve net zero targets and the vision reflects this.
- More clarity is needed on the detail and delivery of the vision and a cohesive landscape design and long-term management plan is needed to support this.
- Good design will be essential in ensuring the right balance between utility and the preservation of landscapes.
- More stringent requirements must be put in place to enforce requirements for landscape mitigation for wind farms in order to achieve planning permission for large scale infrastructure developments (Both on and offshore)
- Delivery of energy infrastructure will require a broad range of skills and additional capacity and landscape practitioners possess many of the key competencies required to support this.
- There is a current skills shortage of landscape architects and other landscape professionals, and the sector should be included in strategies to promote green jobs and benefit from funding initiatives.
- There needs to be more readily available information on the full range of “green energy jobs” and clearer support and pathways into the industry.
- Good planning, design and management will be necessary to ensure that increases in offshore developments do not place unsustainable demands onshore and can be managed in both landscape and environmental terms.
- A landscape and environmental design and management approach is essential when considering the development of bioenergy sites.
- A joined-up design approach is needed in the planning and management of the transition to cleaner energy for transport.
- A wide range of support is needed for the agriculture sector in the move towards decarbonising energy use and should be integrated with measures to increase biodiversity and habitat creation and to improve landscape management.
- We welcome the assessment of the tools and guidance needed to assess the net carbon impacts of development proposals on peatlands and other carbon rich soils.
- Sensitivity will be needed in the roll-out of any guidance and assessments should be made on a case-by-case basis as part of a wider environmental assessment.
(1) – Introduction and Vision
1. What are your views on the vision set out for 2030 and 2045? Are there any changes you think should be made?
We support the ambition of the vision and particularly welcome the commitment to addressing the energy and climate changes crises, while ensuring that biodiversity is preserved and restored. We strongly support the drive to net zero and recognise that a bold and multi-faceted approach will be required to achieve net zero targets and feel the vision reflects this.
More clarity is needed with regards to the detail and delivery of the vision (Although we appreciate that some of the detail will be in supporting strategy and policy documents such as the environment strategy and NPF4), and a cohesive landscape design and long-term management plan will be necessary to support the roll-out. It will be vital to ensure that renewable energy sites, storage and infrastructure are in the right places, and it will be essential to look at existing onshore wind farms to consider how these and their landscapes can be adapted to ensure their longevity.
There is little mention of the word “landscape” in the vision document, despite the widespread impacts that are likely, not least through the increased onshore wind targets. We recognise and support the need for a robust renewable energy sector, however, would note that good design will be essential in ensuring the right balance between utility and the preservation of landscapes.
Better landscape design and management of our landscape and natural environments will ensure that visual considerations are made but will also allow natural environments to accommodate and adapt to change both from a decarbonised energy system and climate change itself. Well-designed, large-scale landscape change will involve increases in native woodland, trees, hedgerows, and shelterbelts which will act to screen views and reduce visual impact but will also increase a landscapes ability to accommodate renewable energy, reduce energy needs, increase biodiversity and habitats, and improve resilience to climate change.
(2) – Preparing for a Just Energy Transition
2. What more can be done to deliver benefits from the transition to net zero for households and businesses across Scotland?
No response
3. How can we ensure our approach to supporting community energy is inclusive and that the benefits flow to communities across Scotland?
No response
4. What barriers, if any, do you/your organisation experience in accessing finance to deliver net zero compatible investments?
No response
5. What barriers, if any, can you foresee that would prevent you/your business/organisation from making the changes set out in this Strategy?
There are current barriers around enforcing requirements for landscape mitigation for wind farms that would be needed for other forms of large-scale development, and this must be addressed to make the changes set out in this strategy.
Typically, renewable energy developments, such as onshore wind farms are assessed as a long term but temporary form of development with an operational life of 20-30 years. This frustrates mitigation requirements and opportunities to provide landscape mitigation which would be necessary for other more conventional and permanent forms of development – for example, by the time trees have grown the wind farm would have ceased operation.
Given that renewable energy is now required ‘In perpetuity’ and at a larger scale, landscape scale management and mitigation is required to protect our environment and increase its ability to accommodate renewable energy, whilst also providing other benefits and increasing resilience to climate change. In effect managing landscape change (For example planning more native trees in the right place can and should take place). More stringent requirements must be put in place in order to achieve planning permission for large scale infrastructure (be it connected to onshore or offshore renewable development), with a greater emphasis placed on long term and large-scale landscape management for change.
6. Where do you see the greatest market and supply chain opportunities from the energy transition, both domestically and on an international scale, and how can the Scottish Government best support these?
No response
7. What more can be done to support the development of sustainable, high quality and local jobs opportunities across the breadth of Scotland as part of the energy transition?
Delivery of energy infrastructure will require a broad range of skills and additional capacity and Landscape practitioners possess many of the key competencies required to support this, including but not limited to:
- Landscape and Visual Impact Assessment
- Seascape Character Assessment
- Planning, legal, policy and regulatory compliance
- Design skills for creating new landscapes and managing landscape change
- Managing landscapes, habitats and species
- Landscape Ecology
- Stakeholder and/or community engagement
- Digital mapping and visualisation (including GIS)
Landscape architects are skilled to provide crucial environmental design and assessment of renewable energy projects across Scotland and landscape effects are often cited as the reason for the failure of a renewable energy scheme to get planning consent. The expertise of highly skilled landscape professionals is needed to overcome these hurdles.
There is a current skills shortage of landscape architects and other landscape professionals, as well as a lack of young people joining the profession who remain in Scotland. Landscape professionals should be included in strategies to promote ‘green jobs’ and to help ensure that the diverse range of opportunities across the sector is fully recognised. It is important that the landscape profession is considered in the updated Climate Emergency Skills Action Plan (CESAP) when determining what skills and jobs will be needed to move towards net zero.
We strongly welcome the ongoing development of the Green Jobs Workforce Academy, and the £100 million green jobs fund, but it is crucial that the landscape sector benefits from this and that there is recognition of the vital role it plays in the well-managed delivery of extensive changes to our energy infrastructure and to the landscape that will be affected by this.
8. What further advice or support is required to help individuals of all ages and, in particular, individuals who are currently under-represented in the industry enter into or progress in green energy jobs?
There needs to be more readily available information on the full range of “green energy jobs” and clearer support and pathways into the industry. Schools career and skills shows / events tend not to focus on green jobs and there seems to be a lack of knowledge about possible career paths. Careers such as landscape planning, management and design related positions will all be essential skills in the transition to achieve the Energy Strategy and Just Transition vision, not just construction and engineering skills.
The Landscape Institute focuses on pathways into jobs in the sector and brings together a network of landscape professionals with expertise, skills and market knowledge. Information is available to people who are interested in moving into the sector through our “Choose Landscape” resources and website. We also commissioned a skills and sector survey to identify trends and issues across the landscape sector, including skills gaps. There are opportunities to work more closely with non-profit organisations such as ours to widen knowledge of the industry and to benefit from their networks and skills knowledge to guide individuals with career choices.
More focus is also needed on targeting under-represented groups, potentially by including a green skills agenda in employability programmes such those under the No-one Left Behind agenda. Funding initiatives and better business support for green apprenticeships would open alternative pathways other than higher education routes. Additionally, it will be necessary to work with universities and colleges to ensure accessible courses for a wide variety of students.
(3) – Energy Supply:
(3.1) Scaling up Renewable Energy
9. Should the Scottish Government set an increased ambition for offshore wind deployment in Scotland by 2030? If so, what level should the ambition be set at? Please explain your views.
We recognise the role that offshore wind will play in achieving net zero targets. A balanced approach will be necessary and whilst a target or number is useful for driving change, it should not be used to unduly limit where opportunities continue to be available, particularly as wind technology and efficiency is changing rapidly with new innovations in technology happening all the time. Traditionally the development of onshore wind had no ‘upper target’ with the industry and the planning system ‘finding its own level’ naturally and this may also apply to the offshore industry.
It is important to note that both onshore and offshore wind deployment will have impacts on the landscape, as offshore wind developments will still require grid and substation sites. Good planning, design and management will be necessary to ensure that increases in offshore developments do not place unsustainable demands onshore and can be managed in both landscape and environmental terms. There may be scope for more sharing of onshore facilities and for offshore substations and grid connections to be used. There are also opportunities for potential offshore developments to be used to increase marine habitat creation.
10. Should the Scottish Government set an ambition for offshore wind deployment in Scotland by 2045? If so, what level should the ambition be set at? Please explain your views.
See previous question.
11. Should the Scottish Government set an ambition for marine energy and, if so, what would be an appropriate ambition? Please explain your views.
No response
12. What should be the priority actions for the Scottish Government and its agencies to build on the achievements to date of Scotland's wave and tidal energy sector?
No response
13. Do you agree the Scottish Government should set an ambition for solar deployment in Scotland? If so, what form should the ambition take, and what level should it be set at? Please explain your views.
No response
14. In line with the growth ambitions set out in this Strategy, how can all the renewable energy sectors above maximise the economic and social benefits flowing to local communities?
No response
15. Our ambition for at least 5 GW of hydrogen production by 2030 and 25 GW by 2045 in Scotland demonstrates the potential for this market. Given the rapid evolution of this sector, what steps should be taken to maximise delivery of this ambition?
No response
16. What further government action is needed to drive the pace of renewable hydrogen development in Scotland?
No response
17. Do you think there are any actions required from Scottish Government to support or steer the appropriate development of bioenergy?
It will be essential to take a landscape and environmental design and management approach when considering the development of bioenergy sites and the associated infrastructure. A robust assessment framework will be needed to assess environmental impacts and ensure that any development is sustainable. Stakeholder engagement will be a critical part of the landscape design process, to ensure that local needs are balanced with wider priorities and objectives.
18. What are the key areas for consideration that the Scottish Government should take into account in the development of a Bioenergy Action Plan?
No response
19. How can we identify and sustainably secure the materials required to build the necessary infrastructure to deliver the energy strategy?
No response
(3.2) North Sea Oil and Gas
20. Should a rigorous Climate Compatibility Checkpoint (CCC) test be used as part of the process to determine whether or not to allow new oil and gas production?
No response
21. If you do think a CCC test should be applied to new production, should that test be applied both to exploration and to fields already consented but not yet in production, as proposed in the strategy?
No response
22. If you do not think a CCC test should be applied to new production, is this because your view is that:
- Further production should be allowed without any restrictions from a CCC test;
- No further production should be allowed [please set out why];
- Other reasons [please provide views].
No response
23. If there is to be a rigorous CCC test, what criteria would you use within such a test? In particular [but please also write in any further proposed criteria or wider considerations ]
- In the context of understanding the impact of oil and gas production in the specifically on the goals of the Paris Agreement, should a CCC test reflect –
- A) the emissions impact from the production side of oil and gas activity only;
- B) the emissions impact associated with both the production and consumption aspects of oil and gas activity (e.also cover the global emissions associated with the use of oil and gas, even if the fossil fuel is produced in the Scottish North Sea but exported so that use occurs in another country) – as proposed in the Strategy;
- C) some other position [please describe].
- Should a CCC test take account of energy security of the rest of the UK or European partners as well as Scotland? If so, what factors would you include in the assessment, for example should this include the cost of alternative energy supplies?
- Should a CCC test assess the proposed project’s innovation and decarbonisation plans to encourage a reduction in emissions from the extraction and production of oil and gas?
- In carrying out a CCC test , should oil be assessed separately to gas?
No response
24. As part of decisions on any new production, do you think that an assessment should be made on whether a project demonstrates clear economic and social benefit to Scotland? If so, how should economic and social benefit be determined?
- In the context of understanding the impact of oil and gas production in the specifically on the goals of the Paris Agreement, should a CCC test reflect –
- A) the emissions impact from the production side of oil and gas activity only;
- B) the emissions impact associated with both the production and consumption aspects of oil and gas activity (e.also cover the global emissions associated with the use of oil and gas, even if the fossil fuel is produced in the Scottish North Sea but exported so that use occurs in another country) – as proposed in the Strategy;
- C) some other position [please describe].
- Should a CCC test take account of energy security of the rest of the UK or European partners as well as Scotland? If so, what factors would you include in the assessment, for example should this include the cost of alternative energy supplies?
- Should a CCC test assess the proposed project’s innovation and decarbonisation plans to encourage a reduction in emissions from the extraction and production of oil and gas?
- In carrying out a CCC test , should oil be assessed separately to gas?
No response
25. Should there be a presumption against new exploration for oil and gas?
No response
26. If you do think there should be a presumption against new exploration, are there any exceptional circumstances under which you consider that exploration could be permitted?
No response
(4) – Energy Demand
(4.1) Heat in Buildings
27. What further government action is needed to drive energy efficiency and zero emissions heat deployment across Scotland?
Although heat in buildings mainly focuses on the built environment, consideration should also be given to the energy saving that can be made for buildings and settlements that benefit from external components such as shelterbelts and community woodlands. These external factors can reduce the need for heat in winter and offer additional cooling in summer, through the creation of micro-climates that can further reduce energy demand and help to address the effects of climate change.
28. What changes to the energy system, if any, will be required to decarbonise transport?
There will be a need for a diversity of sources for energy for transport, which are accessible and widely available. This will include the need for more energy storage facilities and increased energy supply points, including electric vehicle charging points. It is encouraging that the strategy includes plans to expand electric vehicle infrastructure with £60 million being invested in this area, although it is unclear how this will be split between the public and private sector and what Scottish Government’s financial commitment will be.
The changes required will have widespread and lasting effects on the way we design and build both our grid infrastructure and servicing, including roads, car share facilities, parking, train and bus stations, and ferry terminals. It will be important to take a joined-up design approach in the planning and management of these changes and a balance will need to be found between relaxing planning restrictions and permitted development rights enough to allow a timely roll-out of changes whilst ensuring mitigation against negative effects on the landscape, including access and diversity considerations.
29. If further investment in the energy system is required to make the changes needed to support decarbonising the transport system in Scotland, how should this be paid for?
No response
30. What can the Scottish Government do to increase the sustainable domestic production and use of low carbon fuels across all modes of transport?
No response
31. What changes, if any, do you think should be made to the current regulations and processes to help make it easier for organisations to install charging Infrastructure and hydrogen/low carbon fuel refuelling infrastructure?
No response
32. What action can the Scottish Government take to ensure that the transition to a net zero transport system supports those least able to pay?
No response
33. What role, if any, is there for communities and community energy in contributing to the delivery of the transport transition to net zero and, what action can the Scottish Government take to support this activity?
No response
34. Electric vehicle batteries typically still have around 80% of their capacity when they need replacing and can be used for other applications, for example they can be used as a clean alternative to diesel generators. What, if anything, could be done to increase the reuse of these batteries in the energy system?
No response
(4.2) – Energy for Agriculture
35. What are the key actions you would like to see the Scottish Government take in the next 5 years to support the agricultural sector to decarbonise energy use?
It will be crucial that the agriculture sector receive a wide range of support in the move towards decarbonising energy use and the approach should be integrated with measures to increase biodiversity and habitat creation and to improve landscape management.
A whole farm approach will ensure a comprehensive approach to farming and land management, providing a tool for compliance and enabling a stronger regulatory approach. It will be key to bringing together environmental and farming objectives, as well as in supporting giving farmers to access advice and information.
As there is an expectation and need for the farming community to change priorities and practices, there should be financial incentives and funding available to provide stability during this period of transition. The Energy strategy and Just Transition Plan should strongly align with the proposed measures in the Vision for Scottish Agriculture – Proposals for a New Agriculture Bill.
Clear guidance should be outlined around how farmers will be supported and educated to change practice and there is a role for expertise to be shared by professionals in the landscape sector through continuing professional development, training, and knowledge sharing.
(4.3)- Energy for Industry
36. What are the key actions you would like to see the Scottish Government take in the next 5 years to support the development of CCUS in Scotland?
No response
37. How can the Scottish Government and industry best work together to remove emissions from industry in Scotland?
No response
38. What are the opportunities and challenges to CCUS deployment in Scotland?
No response
39. Given Scotland's key CCUS resources, Scotland has the potential to work towards being at the centre of a European hub for the importation and storage of CO2 from Europe. What are your views on this?
No response
(5) Creating the Conditions for a Net Zero Energy System
40. What additional action could the Scottish Government or UK Government take to support security of supply in a net zero energy system?
No response
41. What other actions should the Scottish Government (or others) undertake to ensure our energy system is resilient to the impacts of climate change?
Environmental Impact Assessments already include assessments related to climate change, however there should be more focus on the development of wider plans for the landscape as a whole and a joined-up approach to environmental management. This will not only better protect against climate change but will have multiple benefits connected to biodiversity for example.
(6) Route map to 2045
42. Are there any changes you would make to the approach set out in this route map?
No response
43. What, if any, additional action could be taken to deliver the vision and ensure Scotland captures maximum social, economic and environmental benefits from the transition?
No response
(6.1) Impact Assessment Questions
44. Could any of the proposals set out in this strategy unfairly discriminate against any person in Scotland who shares a protected characteristic? These include: age, disability, sex, gender reassignment, pregnancy and maternity, race, sexual orientation, religion or belief.
No response
45. Could any of the proposals set out in this strategy have an adverse impact on children's rights and wellbeing?
No response
46. Is there any further action that we, or other organisations (please specify), can take to protect those on lower incomes or at risk of fuel poverty from any negative cost impact as a result of the net zero transition?
No response
47. Is there further action we can take to ensure the strategy best supports the development of more opportunities for young people?
No response
(6.2) Just Transition Energy Outcomes
48. What are your views on the approach we have set out to monitor and evaluate the Strategy and Plan?
No response
49. What are your views on the draft Just Transition outcomes for the Energy Strategy and Just Transition Plan?
No response
50. Do you have any views on appropriate indicators and relevant data sources to measure progress towards, and success of, these outcomes?
We welcome the assessment of the carbon calculator system, to gauge whether this is fit for purpose for the energy transition and to ensure that appropriate tools and guidance are used to assess the net carbon impacts of development proposals on peatlands and other carbon rich soils. It is reassuring that an “Expert group” will be convened to provide guidance on the development of onshore wind, particularly in carbon rich areas such as deep peatlands. We would stress however the sensitivity that will be needed in the roll-out of any guidance and that assessments should be made on a case-by-case basis as part of a wider environmental assessment, taking into account carbon calculations, impact on key habitats and biodiversity and visual impacts on the landscape.
About the Landscape Institute
The Landscape Institute (LI) is the chartered body for the landscape profession. We are an educational charity that promotes the art and science of landscape practice.
The LI’s aim, through the work of our members, is to protect, conserve, and enhance the natural and built environment for the public benefit.
The LI provides a professional home for all landscape practitioners including landscape architects, landscape managers, landscape planners, landscape scientists, and urban designers.
About LI policy and research
The LI undertakes research, builds networks, and provides policy advice to local and national policymakers, regulators, and stakeholders. We seek to demonstrate how landscape and green infrastructure can deliver maximum benefits for society, the environment, and the economy.
The work of the LI policy team is overseen by the LI Policy and Communications Committee (PCC), one of three standing committees that report to the LI’s Board of Trustees.
Contact
Hazel Benza, Policy and Partnership Manager Scotland and Northern Ireland
hazel.benza@landscapeinstitute.org | 0330 808 2230
About the Landscape Institute
The Landscape Institute (LI) is the chartered body for the landscape profession. We are an educational charity that promotes the art and science of landscape practice.
The LI’s aim, through the work of our members, is to protect, conserve, and enhance the natural and built environment for the public benefit.
The LI provides a professional home for all landscape practitioners including landscape architects, landscape managers, landscape planners, landscape scientists, and urban designers.
About LI policy and research
The LI undertakes research, builds networks, and provides policy advice to local and national policymakers, regulators, and stakeholders. We seek to demonstrate how landscape and green infrastructure can deliver maximum benefits for society, the environment, and the economy.
The work of the LI policy team is overseen by the LI Policy and Communications Committee (PCC), one of three standing committees that report to the LI’s Board of Trustees.
Contact
Hazel Benza, Policy and Partnership Manager Scotland and Northern Ireland
hazel.benza@landscapeinstitute.org