Open letter: Wind developers call on the Secretary of State to clarify the 2035 onshore wind permitted capacity for Scotland
In March 2025, Low Carbon joined its voice with 12 other wind developers in Scotland in an open letter to Ed Miliband, the energy secretary, calling for an urgent rethink of the figures set out in the Clean Power 2030 Action Plan, warning that billions of pounds of investment is at stake.
The Rt Hon Ed Miliband MP
Secretary of State for Energy Security and Net Zero
Department for Energy Security and Net Zero
55 Whitehall
London
SW1A 2HP
Open letter: Scottish onshore wind developers call on the Secretary of State to clarify the 2035 onshore wind permitted capacity for Scotland in the Clean Power Action Plan amid concerns of a de-facto ban on Scottish onshore wind post-2030.
Monday 3 March 2025
Dear Secretary of State,
We, the undersigned group of onshore wind developers, are writing to express our significant concerns about the 2035 onshore wind capacity permitted for Scotland in the Connections Reform Annex of the Clean Power Action Plan (CPAP).
Currently, the cap in the CPAP will allow only 700 MW of additional Scottish onshore wind capacity to connect between 2031 and 2035. This would result in a decrease in the rate of installations allowed after 2030 of over 90%, and amounts to a de-facto ban on Scottish onshore wind post-2030.
Even more perversely, the caps are so low that many Scottish onshore wind projects that have already submitted planning applications will be told that they are no longer needed and that they will be kicked out of the grid queue. This includes projects with existing connection dates of around 2030 that are on track to contribute to the Government’s ambitious mission for Clean Power by 2030.
The 2035 cap on Scottish onshore wind not only risks hundreds of millions of pounds of investment that has already been committed to or spent on developing projects, it would switch off billions of pounds of planned investment and would undermine the Government’s ultimate goal of speeding up the deployment of clean power. This appears particularly absurd, given the hundreds of jobs that can be created from one of the fastest and lowest cost forms of generating clean power.
The Strategic Spatial Energy Plan (SSEP) will be published too late to solve the problem.
NESO and DESNZ have indicated that the 2035 figures may be revised through the upcoming Strategic Spatial Energy Plan (SSEP). However, this will happen too late for projects intending to deliver in the early 2030s. The SSEP is also very unlikely to capture all development given the widely distributed nature of onshore wind developments and should only ever be indicative and
not comprehensive. There also remains some uncertainty around how the SSEP will interact with and not undermine devolved responsibilities under the Scottish National Planning Framework.
The SSEP is due to be published in Q4 2026, which would mean additional grid offers being issued in Q3 2027. This is far too late for Scottish onshore wind projects seeking to connect in 2031, 2032 or 2033, taking into account timelines for consenting, procurement and construction.
Recent statements from DESNZ Head of Mission Control, Chris Stark, suggest that the Government may not be aware of the post-2030 de-facto ban that it is implementing.
We welcome the recent comments by Chris Stark, at an Institute for Government panel event, where he publicly stated that it is “certainly not the intention to apply a de-facto ban on onshore wind in Scotland post-2030.” He emphasized that DESNZ sees “opportunities to grow the supply of onshore wind quite significantly” across both Scotland and England.
However, this contradicts what is currently in the CPAP, which restricts post-2030 Scottish onshore capacity to just 700 MW.
While Chris Stark suggested that these are merely “objectives” rather than “caps,” in practice they function as hard caps that create investment uncertainty and halt vital development activities that must take place now so that projects can deliver in the early 2030s. (given the long lead time between development and operations which is typically several years).
During the same panel discussion, NESO CEO, Fintan Slye referenced the SSEP as looking beyond 2030 to 2035 and 2040; however, as already stated, the timeline for that process means crucial projects will be stalled or delayed until well into the 2030s, causing an investment hiatus now and a lack of projects available to connect in the early 2030s.
Low caps for Scottish onshore wind will reduce competition in CfD auctions and therefore push up energy bills.
One of the key aims of the Clean Power Mission is to reduce energy bills, which requires strong competition in CfD auctions. The current capacity “caps” (or “objectives”) for onshore wind, solar, and battery storage in the CPAP artificially limit the pipeline of projects. NESO’s analysis has not fully considered the technology-specific implications for competition — especially in Scottish onshore wind — and has not accounted for inevitable attrition in projects that fail to reach financial close or receive planning consent.
For instance, while the Plan allows 20,500 MW of onshore wind in Scotland by 2030 (an 11,000 MW net increase from current levels), it then caps new capacity at just 700 MW beyond 2030. With only 700 MW in the 2035 “bucket,” there is insufficient oversupply to generate meaningful competition for CfD auctions even in the period to 2030. Additionally, no account appears to have been taken into attrition of current projects that will need to go back into planning for larger modern turbines, delay through planning nor the practicalities of supply chain resource availability. This undermines the cost-effectiveness gains that come from genuine competition among multiple qualified projects. If it is the case that government means ‘minimum volumes’ rather than ‘caps’ this should be explicitly stated, and nevertheless a much higher level between 2030 and 2035 should be illustrated.
Cost competition from Scottish onshore wind is also critical for other forms of clean power generation—including projects in England, Wales, and floating offshore wind. If, for example, floating offshore wind proves more expensive or even slower to deliver than expected, then the Government is leaving itself no flexibility to procure more onshore wind to compensate (as the CPAP bans those onshore wind projects from connecting to the grid).
We urge the Government to clarify the 2035 onshore wind permitted capacity for Scotland in the Clean Power Action Plan. We believe the solution is for the Government to increase the 2035 cap for Scottish onshore wind in the CPAP before the end of May 2025 and that without this action, many well-advanced Scottish onshore wind projects will be kicked out of the grid queue, including projects that are on-track to deliver by 2030.
Yours sincerely,
The undersigned group of onshore wind developers:
