[Note to LPG followers: The consultation is here and closes on 29 January 2026. If you only have time to answer one question, please make it Question 11 Energy Supply. What are your views on Scotland generating more electricity from renewable sources? An email response is only valid if you complete and attach the first two pages of this form]
Lauderdale Preservation Group is a local conservation group in the Scottish Borders, established in 2010 to protect our environment, principally from the threat of overbearing and inappropriate energy installations. We are not against sensitive, economically viable, renewable energy projects.
1. Just Transition
LPG has concerns that a blinkered rush to reduce Scotland’s already miniscule carbon emissions risks wreaking extensive damage on our natural environment.
The Scottish Government’s current plans to transition to what it considers a low carbon economy are unjust, environmentally unfriendly and socially and economically destructive. The ecology of our tangible environment is directly threatened by the Scottish Government’s reckless planning policies. In particular Section 11 of National Planning Framework 4, that prioritises industrial installations in hitherto rural places.
The basic idea that Scotland can make an impact on global climate averages is conceited hubris. Given that the whole policy depends on offshoring emissions to other countries, it is also deceptive.
Britain is considered to emit 0.8% of all human carbon emissions. Scotland is 8% of that so 0.064% of humanity’s total emissions. Most terrestrial decarbonisation is dependent on other countries, principally China, burning coal on our behalf. Such policies do nothing to reduce global emissions.
Britain as a whole, including Scotland, has already reduced electricity generation carbon emissions by 80% since 1990. Cutting the last 15%, with wind and solar power (including compensation) would come at unacceptable landscape, nature and economic cost.
The resulting reduction in global carbon emissions would be negligible – 1000ths of a percentage point.
The term Just Transition means ramming through harmful policies against the wishes of rural and what is left of industrial communities.
2. Sectoral Contributions
Question 11 Energy Supply. What are your views on Scotland generating more electricity from renewable sources?
Scotland’s current electricity demand ranges from 3GW with occasional peaks at 5GW. In Scotland as in the rest of Britain, electricity demand has fallen over 20% in the past 20 years since net zero policies first started to push up electricity prices.
2024 data
Scotland consumed 21.68 TWh of electricity in 2024 (UK Gov)
17.6 GW of renewable electricity capacity was installed by the end of 2024 (Scot Gov)
Of which:
10.3 GW onshore wind
4.1 GW offshore wind
1.6 GW hydro
0.7 GW solar
0.6 GW other
38.4 TWh of renewable electricity was generated (so the output was around 25% of installed capacity)
Firm power Torness produced 8.7 Twh in 2024 at 75% of installed capacity
Dispatchable Peterhead gas power station can produce up to 10 Twh in a year
Total power generation in Scotland 2024, between 47 – 57 TWh
19.7 TWh of net electricity exports to England and Northern Ireland. Data is not available on the origin of all this.
Given the firm power from Torness, Scotland can’t have used more than 13 TWh of the ‘renewable’ energy. Data for Peterhead gas power is not easily available but it would have been used to plug gaps in wind power. Also data on electricity imported from generators in England is not easily available but on cold still days, Scotland needs back up firm power from England.
By the end of 2024 Scotland had already over installed wind capacity by a factor of three times peak or five times regular demand. The output of 30 TWh was in theory 150% of total demand but not in practice.
When Torness goes offline in 2030 Scotland will lose 40-50% of its total electricity supply and most of its firm reliable electricity. Building more unreliable capacity does not compensate for that loss.
The challenge for Scotland is not to send more electricity south on windy days but to ensure future firm power for still periods.
As of 2024 there is already a significant mismatch between supply and demand. The headline figures sound impressive, but the reality is a poor return for the loss of nature and landscape.
Solar Power in Scotland
Scot Gov has an arbitrary ambition to install 3GW of solar panels across Scotland.
Electricity Output
Thanks to Scotland’s latitude, solar panels give out 1-2% of capacity in winter when demand is greatest. In summer, when demand is lowest, it puts out a glut. As such, solar does not make a useful contribution to the grid.
Wildlife
Several field studies have demonstrated beyond doubt that solar farms are dead zones for bats. Solar farms are in direct opposition to biodiversity as far as bats are concerned.
Landuse
Solar is estimated to take 50 times as much land as nuclear for equivalent output. But solar is virtually useless in Scotland in winter, unlike nuclear power.
Onshore Wind
Scot Gov has an arbitrary ambition to install 20GW onshore wind by 2030
10.4 GW is already in operation and 7.6 GW is in train so 18 GW is already assured.
A further 10.4 GW of onshore wind is in the planning system. By the Scottish Government’s own targets, most of these applications should be rejected.
Electricity Output
It wouldn’t matter if wind power could be relied on 99% of the time, Scotland would still need firm power on standby 365 days a year for use 3 ½ days a year. The fixed costs of maintaining reliable power stations would all be loaded onto those 3 ½ days. Or Scotland would depend on firm power (gas or nuclear) from England at those times. We must prioritise firm power. Nuclear power generates zero carbon emissions, is totally reliable and takes a tiny land use footprint. Gas power has low emissions, both reliable and flexible and takes a tiny land use footprint.
Land use per MW
Onshore wind comes at considerable and destructive land use cost. This cost is further extended by large scale BESS battery installations and additional grid infrastructure.
Wind power needs 500 times as much land to produce the same energy as nuclear power. But nuclear power is reliable and self contained. Wind power is temperamental and creates a market for large scale BESS systems, which are also land hungry. Located a long way from demand, windfarms also necessitate additional power lines. If Holyrood persists with its policy of consenting windfarms at all costs, NESO will justify building a new onshore powerline and dozens of substations through rural Scotland.
Scottish Government can and should use its devolved planning powers to spare our landscape and say no to intrusive plans for additional infrastructure.
Habitat and wildlife costs
Windfarms are not environmentally sound for the following reasons:
- Several kilometres of wide, well drained access tracks must be built, disturbing hydrology and drying out the ground
- Every windfarm involves the loss of peat to varying extent
- All habitats have biodiversity value and windfarms, particularly the access and foundations always involve habitat destruction: acid grassland, moorland, scrub, peat bogs, woodland, meadows
- Turbines kill birds, particularly raptors and migrating birds
- Turbines disorientate and kill bats. Developers estimate 5 bats a month are killed per turbine. Multiplied across the thousands of turbines in Scotland that is a bat genocide every year.
Carbon Emissions
The carbon emission saving claims of onshore windfarms are exaggerated.
- Some wind speculators make false claims about net output
- DESNZ has revised its capacity factor down by 25% (October 2025)
- At least 5% of a wind turbine’s annual output is sucked back into restart the blades after curtailment or lull and to keep the blades turning during low and erratic wind speeds
- Onshore wind turbines currently manage to put out 25% of installed capacity. By trebling the size of turbines that might increase to 30-35%. However some speculators claim over 40% capacity and base their (spurious) carbon emission claims on that.
- Gordon Hughes’ work shows that turbine output also declines over time
Wind subsidy speculators also underestimate the build and maintenance carbon cost:
- The carbon costs of a turbine are not publicly explained, so we have no way of knowing whether they are accurate
- The carbon costs of steel rebar are not included in calculations
- Peat carbon loss calculations are underestimated and assume minimal peat drying from large drainage ditches.
- Each windfarm comes with a small substation, the carbon costs of which are omitted from calculations
- Windfarms now come with BESS batteries to smooth out erratic wind energy output on its way to the grid. The carbon costs of a BESS installation is omitted from calculations.
- The infrastructure carbon costs have never been accounted for. This might be a line of wooden poles several miles to the nearest substation.
- Under NESO’s RII03 proposals most post 2030 onshore windfarms would be liable for a share of the carbon cost of major new powerlines and substations through Scotland.
- The construction carbon costs, such as tens of thousands of vehicle movements or the cost of rearranging public roads are also omitted from calculations.
Similar questions about the true carbon costs apply to solar and offshore windfarms.
The Scottish Government seems to be complicit in this misinformation about the carbon costs and energy outputs of windfarms. The Scottish Government’s enthusiasm for windfarms thus calls into question whether its concern for global average temperatures is genuine or a cover to justify the deeply unpopular and environmentally irresponsible destruction of Scotland’s landscapes.
The wind lobby claims that covering upland Scotland in giant steel towers is necessary to save the planet. This is not true. The carbon emission claims are firstly exaggerated, secondly negligible either way. However the nature and landscape costs are real and significant.
Infrastructure
Lauderdale already hosts six windfarms in the hills that define the Royal & Ancient Burgh.
However, like other rural communities the length of Scotland, we are threatened by major infrastructure developments. New substations and powerlines would introduce alien overbearing industrial elements. They would also enable a major expansion in wind, solar and battery farms. See above for why we say that is poor environmental stewardship.
We hope the Scottish Government will see sense, stand up for Scotland and refuse planning permission for unnecessary grid expansion. The supposed justification for a new powerline is to reduce constraints payments. But a new powerline and substations only enable even more windy day electricity surplus. Rural Scotland from north to south would be scarred at vast expense and still the windfarms would be turned off at further cost to bill payers.
Q14 What do you think about our proposals for planting trees and restoring natural habitats like peatlands?
Planting native woodland and restoring damaged peat are both welcome. However thousands of hectares of natural habitat such as peatland are destroyed in the name of green energy. Tens of millions of trees have been felled to make way for onshore windfarms in Scotland.
Private landowners are legally bound to replant felled trees and keep forestry land in use. The same rules don’t seem to apply to energy speculators who make vague, un-enforceable promises about mitigating loss elsewhere.
We support habitat restoration, but this proposal smacks of greenwashed hypocrisy when the Scottish Government forces through dozens of landscape and habitat destroying energy applications every year.
The Nature Crisis referred to in National Planning Framework 4 is driven by habitat loss, not by climate change. As long as the Scottish Government keeps consenting industrial projects across the landscape it enables biodiversity loss.
Q16 Which groups or communities do you think will be most affected by the transition to net zero and in what ways.
On the current ill conceived net zero trajectory there are winners and losers
Winners:
- Financiers who buy a windfarm subsidy guarantee
- Shareholders in the transmission monopolies SSEN and Scottish Power
- (short term) Landowners
Losers:
- Rural communities – loss of landscape and nature
- Young people – loss of jobs and opportunities as the real economy withers away. Already over 15% of 16-24 year olds in Scotland are Not in Employment, Education or Training. An indictment of current energy policy.
- Everyone in Scotland – our beautiful landscape destroyed, economy run into the ground
- (long term) Landowners left with industrial clutter littering their land when the subsidy regime changes. Intermittent energy sources will no longer be economically viable without substantial market manipulation.
- Tourism industry
- Nature and wildlife
Q23 What in your view are the most significant environmental effects which should be taken into account as the Draft Climate Change Plan is finalised?
Destroying rural Scotland will not save planet earth from a ‘Climate Emergency’. On the contrary, Scotland should contribute to the health of our world with abundant nature and biodiversity.
National Planning Framework 4 must be rewritten; remove chapter 11 that prioritises energy infrastructure at all costs and against all common sense.
Stop building more sprawling, low density, intermittent energy installations. The Scottish Government should refuse to participate in NESO’s additional grid plans. Furthermore, the Scottish Government should be holding NESO to account for misleading statements and conduct in their reporting (https://davidturver.substack.com/p/what-is-the-point-of-neso).
Q30 What are the most appropriate indicators for judging whether we are achieving meaningful public participation in decisions related to the climate? This includes both the quality of the participatory process itself and the impact of that participation on the decision making process.
National Planning Framework 4 pays lip service to the importance of nature and landscape, while prioritising wide ranging industrialisation in section 11. Section 11 should be removed from NPF4 as a matter of urgency.
Hand energy planning decisions back to local authorities. Cancel the centralising power grab by Holyrood.
The notion that Scotland’s actions to reduce 0.064% of emissions would have an impact on global climate is beyond parody. However this delusional thinking is causing real life damage to Scotland’s biodiversity, landscape and nature restoration prospects.