This document was submitted to the Scottish Executive in response to the consultation paper 'Scotland's Renewable Energy Potential – Beyond 2010'. The consultation paper can be downloaded from the Scottish Executive website.

Introduction
The Mountaineering Council of Scotland (MCofS) is the representative body for hillwalkers, climbers and off-piste skiers and receives core grant funding from sportscotland in recognition of this status. We are a membership organisation with about 2,000 individual members plus 130 affiliated clubs that contain approximately 7,000 members. Our Committee structure is entirely voluntary and appointments are the result of a democratic process. The professional staff complement is made up of four posts at our Perth office.

The MCofS welcomes the opportunity to respond to this consultation, which concerns the future development of renewable energy in Scotland and the likely impact that will have on the wild and mountainous areas of this country.

The MCofS responded to the draft NPPG6 consultation in 2000, and whilst our comments were not acted upon at that time, we are pleased to see some of those ideas coming through in the Executive's thinking in this consultation paper. As part of our ongoing interest in renewable energy issues we have the following comments to make in relation to this current consultation exercise.

The MCofS welcomes the Scottish Executive commitment to set a target such as 40% of Scotland's electricity from renewable sources by 2020. In seeking to achieve such a bold target, however, there must be great care taken not to cause irreparable damage to our finest landscapes. Many forms of renewable energy rely on harnessing power in remote rural locations, where it would not be considered appropriate to build a conventional power station. In securing energy from natural sources there is often a requirement to develop a form of power station in such areas and this is our main concern that we wish to discuss in this response.

Key Concerns
Whilst we do admire the commitment to achieve this 40% by 2020 target, and agree that it would be a significant contribution to the reduction in greenhouse gases that is urgently required, we believe that the main commitment over this period should be research into the longer-term future of renewables. The forms of renewable energy that can be developed at the moment produce relatively small amounts of power, and the amount of fossil fuel derived power required to construct them can often lead to a long time delay until a scheme is actually producing a net saving in power. Whilst any net gain is a worthwhile contribution, we believe there should be more commitment to searching for methods of harnessing much greater amounts of natural energy in the future, rather than searching for lots of small schemes that are expensive in terms of fossil fuel use and landscape damage. We believe that natural energy should be harnessed now, but instead of pursuing numerous controversial schemes, the schemes that are developed should be part of a much greater emphasis on research into building much bigger and more efficient schemes in the future. This kind of policy would lead to a greater possibility of achieving targets in the longer-term, for example the target quoted in the consultation paper of 60% by 2050.

We are pleased to see reference to "sharply improving energy efficiency" in the consultation paper. This is a point that we stressed in our NPPG6 consultation response. In our view this has to be a major priority, and must now be taken seriously. We understand that Scotland's use of energy is currently rising faster than our development of new power from renewable sources. Whilst our percentage of energy from renewable sources may be increasing, our overall use of non-renewable sources is also increasing. This may help our nation to claim it is achieving percentage-based targets, but we will only be making a worthwhile contribution to the global effort when the amount of non-renewable energy we are using begins to fall. The most obvious way to achieve this is by making a concerted and serious attempt to address the issue of energy efficiency. This is not just about campaigns to turn lights off and heating down, but is primarily about actively encouraging the use of more energy efficient materials in our homes and workplaces.

Turning now to the landscape impact of renewable energy schemes, we believe that a relatively small number of the more controversial schemes lead to a significant amount of bad publicity and this gives renewable energy an unfortunate and unwelcome public image. We agree that it is important to raise awareness and acceptance of the benefits of renewable energy, but this requires the most controversial schemes to be avoided, as they are the ones that contribute to this negative image. The worst schemes set conservationist against conservationist, and alienate the very people who should be most in favour of renewable energy. Our view is that forcing unpopular schemes through the planning system is the wrong way to go about gaining public acceptance and understanding of renewable energy, and yet this sometimes appears to be the UK government's policy.

Our greatest concern at this current time is the considerable impact of wind farms on Scotland's upland landscapes. From the correspondence received at our office, this is the main conservation concern for our members at the current time. Scotland's mountains and hills are attracting considerable attention from wind energy developers, and we fear that a great deal of permanent damage is about to be inflicted on our mountains, but with a poor return on energy output for the amount of damage. It is simply not the case that wind turbines can be removed in future years with no long-term damage to the ground. As well as the impact of concrete and steel on the ground, there is often the even greater impact of unsightly bulldozed roads leading to wind farms. The altitude and latitude of Scottish mountains are such that vegetation takes many years to recover, and in places recovery will never take place at all.

There are many brown field sites that are less controversial and far more likely to be acceptable to the public who have to live near to, or look at these structures in otherwise scenically attractive areas. By way of example, we believe that many harbours and other industrialised parts of the coastline would have sufficient wind speeds to be of interest to wind energy developers. Indeed, the long-term future of wind energy is likely to be in offshore developments where the wind is stronger and smoother.

Sympathetically sited offshore wind turbines should have far less visual impact on landscapes, but in order to build such structures there will need to be a significant investment in research to provide us with the necessary technology and engineering capability. The bulk of research resources over the past few years have been diverted into the nuclear industry, and this has had the effect of restricting the progress of renewable energy knowledge and potential.

We are particularly concerned with references in the consultation paper to a "positive planning environment", which suggests a relaxation of environmental protection. Despite a wide range of nature conservation designations in this country, there is very little protection of landscape qualities. We believe that developers who fail to see the attraction in our finest landscapes, many of which do not fall within National Parks and National Scenic Areas, can easily exploit this. We would like to see a strengthening of the system for protecting landscapes and believe that there must be rigorous scrutinisation of each individual project for its environmental impact. This is crucial and there must be no relaxing of standards to allow renewable developments an easier passage through the planning system.

The majority of renewable energy schemes coming forward at the moment are dominated by wind power proposals, and these are followed by small-scale hydro. Both of these energy types have a significant impact on the upland areas of Scotland, and this impact could be lessened if other forms of energy could be developed and more widely adopted. We have already mentioned offshore wind, but there is also wave and tidal power, which will require considerable research investment if we are to realise the massive potential these marine energy forms can offer. Then there is biomass, which holds some potential, albeit probably not as much as the other forms of renewable energy. There are also photovoltaics, which appear to us to hold a great deal of potential, and this is another area where a massive amount of research is needed. A wider recognition of their benefits could lead to an expansion of the manufacture of photovoltaics and more widespread use would lead to cheaper costs of purchase and installation. We believe that government should do all it can to encourage the development and use of photovoltaics. Furthermore, we totally support the concept of really small-scale renewable energy projects on the roof of a home or office, or in the garden.

Conclusion
To briefly draw our comments together, we believe that the government is right to set bold targets for developing renewable energy, but this should be balanced alongside the need to fund research into the more efficient use of renewable energy in the medium and long-term future. We also believe that there should be no relaxation in the planning system, that landscape protection should be taken seriously, and that the most controversial schemes should be avoided as they lead to bad publicity and public resistance to renewable energy schemes. It is also important that one or two types of renewable energy do not dominate, and that other forms of electricity generation are allowed to develop and contribute towards future generation targets. Finally, the basis for our nation's energy policy must be firmly based on the principle of energy efficiency. This has not been taken seriously in the past, and an outcome of this consultation must be to radically improve on our woeful waste of energy. Reducing our total consumption of energy must be our main priority.

29 November 2002