UK To Introduce Deposit Return Scheme For Single-Use Plastic Bottles

March 29th, 2018 by

A deposit return scheme for single-use plastic drink bottles will be introduced this year in the UK, with the idea being to improve the rate of plastic bottle recycling and thus to reduce litter.

The new plans echo some of those put into place in recent years in a number of other countries in the region (and elsewhere in the world, as well), including in Germany, Sweden, and Denmark.

To provide a basic overview: customers are charged a bottle deposit when buying a drink in a plastic bottle, which can then be redeemed for money or store credit (often via automated return systems) if brought back empty.

The UK’s environment minister Michael Gove was quoted in a public statement on the matter as saying: “We can be in no doubt that plastic is wreaking havoc on our marine environment — killing dolphins, choking turtles, and degrading our most precious habitats. It is absolutely vital we act now to tackle this threat and curb the millions of plastic bottles a day that go unrecycled.”

The new plans are subject to public consultations later this year, reportedly.

Reuters provides more: “British consumers get through about 13 billion plastic drink bottles a year but more than 3 billion are either incinerated, sent to a landfill, or left to pollute streets, the countryside, and marine environment, the government said…The consultations will focus on the details of how the scheme will work along with other measures to increase recycling rates.

“A possible alternative to the deposit return scheme is cash rewards for returning drink containers, the government said. This is often executed by a network of ‘reverse vending machines’ through which a plastic or glass bottle can be inserted into one and the machine returns money.”

These plans follow on the imposition of mandatory plastic bag fees in the UK in 2015 and represent part of a broader push to reduce plastic litter. While such plans aren’t enough on their own to “deal with” the vast problem of plastic pollution, they would/will likely to help to reduce it to a notable degree.

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About the Author

James Ayre's background is predominantly in geopolitics and history, but he has an obsessive interest in pretty much everything. After an early life spent in the Imperial Free City of Dortmund, James followed the river Ruhr to Cofbuokheim, where he attended the University of Astnide. And where he also briefly considered entering the coal mining business. He currently writes for a living, on a broad variety of subjects, ranging from science, to politics, to military history, to renewable energy.

Renewable electricity generation up by 26% in Scotland

Renewable electricity generation in Scotland increased by over a quarter last year, according to official data.

Statistics published by the UK Government show an increase of 26% in 2017 compared with the previous year.

The majority of the rise was attributed to greater onshore wind capacity.

Renewable electricity generation increased in 2017 (Danny Lawson/PA)

Renewable electricity generation increased in 2017 (Danny Lawson/PA)

Renewable electricity generation increased in 2017 (Danny Lawson/PA)

The increase meant that, at the end of the final quarter of the year, a record 10GW of installed renewables electricity capacity was operational in Scotland, a 13% increase over the year from the final three months of 2016.

It is estimated the equivalent of 68.1% of gross electricity consumption in Scotland came from renewable sources, up 14.1 percentage points from 54% in 2016.

Energy Minister Paul Wheelhouse said the figures demonstrated the renewables industry is “stronger than ever”.

“Scotland’s Energy Strategy recognises and builds on our achievements to date and on our country’s capacity for innovation,” he said.

“Renewable energy will play a hugely significant role in powering Scotland’s future and through the strategy we want to ensure the correct strategic decisions are taken to support this much valued sector of Scotland’s economy as it goes from strength to strength.”

Claire Mack, Scottish Renewables chief executive, added: “These figures show Scotland as a renewable energy powerhouse, producing more electricity than ever and transferring much of it to markets in the rest of Great Britain, all the time reducing carbon emissions from our power sector.”

Sturgeon: Scotland´s renewables industry at risk from...

A hard Brexit could damage Scotland’s renewables industry by cutting off access to vital labour and funding, Nicola Sturgeon will warn.

Scotland’s First Minister will urge the  UK Government to provide clarity on the future of the sector as she addresses the Scottish Renewables annual conference in Edinburgh.

The speech falls in the week that marks one year until the UK is due to exit the European Union (EU).

First Minister Nicola Sturgeon will warn Scotland´s renewables sector is at risk from a hard Brexit (Andrew Milligan/PA)

First Minister Nicola Sturgeon will warn Scotland´s renewables sector is at risk from a hard Brexit (Andrew Milligan/PA)

First Minister Nicola Sturgeon will warn Scotland´s renewables sector is at risk from a hard Brexit (Andrew Milligan/PA)

Ms Sturgeon will highlight the importance of the industry to Scotland’s economy, with more than a third of the UK’s renewable energy produced north of the border.

She is expected to say: “Scotland has internationally recognised research expertise in renewables.

“We also have incredible renewable resources, and a long history of engineering excellence. Those assets give us the basis for a thriving renewables sector and supply chain.

“Brexit makes this work rather more challenging. If we are taken out of the single market, it will hinder our supply chain and reduce our skills base.

“If we are outside the internal energy market it could affect our influence on issues such as energy regulation and cross-border energy flows, something which is of increasing importance.

“And, arguably more damaging to our ambitions, we could also lose access to EU funding.

“Scotland has benefited from one of the biggest investments ever made by the European Investment Bank – the £500 million of funding they provided for the Beatrice offshore windfarm.

“Scotland has also done disproportionately well from EU support for research and innovation in the renewables sector. We want that to continue.

“Although the overall outlook for this sector is hugely positive, we need the UK Government to provide clarity on these points. A hard Brexit could potentially cause harm to our supply chain and skills base; our influence on big decisions on issues such as regulation and energy flows; and our access to funding.

“It’s a good example of why arguing for the least damaging approach to Brexit – for continued single market and customs union membership – is a core part of the day to day business of government.”

UK hints at onshore reprieve

Energy Minister says wind and solar price support auctions 'to return'

UK hints at onshore reprieve image

UK Energy Minister Claire Perry has given the clearest indication yet that onshore wind and solar will feature in future price support auctions for renewables.

Speaking to Parliamentary magazine The House in a wide-ranging interview, Perry said the UK government “will have another auction that brings forward [onshore] wind and solar, we just haven’t yet said when.”

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The minister gave no indication on timelines for any Contracts for Difference (CfD) auction including so-called Pot 1 renewables.

BEIS barred established technologies from competing in last year’s CfD2 auction after the Conservatives pledged to end subsidy for onshore wind in its 2015 general election manifesto.

The Tories’ 2017 election manifesto opened the door to a reprieve in Scotland and Wales, however, after the party stated “we do not believe more large-scale onshore wind power is right for England.”

Energy department BEIS is “looking carefully” at onshore wind expansion in Scotland and Wales, Perry explained to The House, which is often described as Parliament’s in-house journal.

Westminster said last year it is exploring a price mechanism that would allow new onshore wind projects to be built in a cost-neutral environment in Scotland and Wales.

Perry told Parliament last November that energy department BEIS is “actively working” on ways to facilitate projects outside of England.

The minister stated in a written Parliamentary answer earlier this month, however, that “no decisions have been taken on future Contract for Difference allocation rounds for established technologies”.

Image: BEIS (Steph Gray)

NatWest Surpasses Sustainable Energy Target By Providing £3.5 Billion of Lending to UK Renewable Energy & Energy Efficiency Projects

NatWest announced this week it has beaten its sustainable energy funding target, providing £3.5 billion of lending to UK renewable energy and energy efficiency projects over the past three years. The bank reported it set a three-year target of £3 billion in 2015 and is now committed to funding £10 billion to the sustainable energy sector by 2020 to help accelerate the transition to a low carbon economy. Speaking about the milestone, Richard Saint, Managing Director of Energy Infrastructure & Industrials at NatWest, stated:

“This is a huge achievement, demonstrating our strong commitment to the low carbon economy and the jobs, businesses and communities that rely on it. It also highlights the attractiveness of the UK for investment in the low carbon goods and services sector for British businesses.”

The latest milestone comes less than a month after NatWest announced it is launching four specialist fintech accelerators based in its Bristol, Edinburgh, Londo, and Manchester hubs. According to NatWest, up to 80 fintech businesses will benefit from Dell EMC’s expertise through regular technology reviews and sales strategy analysis.

NatWest noted that The NatWest Entrepreneur Accelerator hubs are located in Birmingham, Brighton, Bristol, Cardiff, Leeds, London, Manchester, Milton Keynes, and Newcastle. Hubs in Edinburgh and Glasgow will be Royal Bank of Scotland Entrepreneur Accelerators, while the Belfast hub will be known as the Ulster Bank Entrepreneur Accelerator. All support is provided to entrepreneurs fully funded with no strings attached.

NatWest also recently announced it has come to an agreement with Entrepreneurial Spark to transfer its network of 12 entrepreneur accelerator hubs to be 100% managed by the bank.

MSP calls for clarity on Westfield incinerator plans

Concerns have been raised in Hollyrood over the number of incinerators that may be sited at the former Westfield opencast colliery site on the outskirts of Kinglassie.

Mark Ruskell, Green MSP for Mid Scotland and Fife, raised the issue of the Westfield masterplan at the Scottish Parliament during a debate on incinerators and planning policy, warning that there could soon be a rush of new incinerators if ministers do not tighten up waste regulations.

Mr Ruskell’s concerns followFife Council approved a masterplan for the former open cast coal mine near Kinglassie which included a 20 megawatt energy-from-waste facility.

The facility would burn waste from homes across Fife to create energy to be used locally.

Mr Ruskell claimed not all local residents had yet been made fully aware of the incinerator plan, as the developers focused on renewable energy generation and public access works when presenting the plans.

Speaking after the debate, Mr Ruskell told the Gazette; “We heard from MSPs from across the country who represent communities fighting plans for new incinerators.

“So much of it resonated with the situation at Westfield – residents feeling like they have not been adequately consulted, their concerns have not been listened to, and a planning system which is not geared up to deal with this new shift towards burning household rubbish.

“The masterplan at Westfield contains great potential, outlining how the site could be used for renewable energy facilities and turned into a local natural amenity.

“However I have real concerns about how decisions over where and how many incinerators to build are being made, and I’m not convinced planning policy has this issue under control.

“Decisions are being led by private developers and not a coherent plan from Government.”

Mr Ruskell met with Scottish Environment Minister Roseanna Cunningham and Paul Wheelhouse, Scottish Minister Minister for Business, Innovation and Energy, to discuss the concerns.

“They’ve promised to look at producing a better assessment of what Scotland’s incineration needs will be once new bans on sending waste to landfill come in in 2021,” said Mr Ruskell.

“I hope this will result in clearer guidelines being put in place before any final decision is made about including an incinerator in the Westfield redevelopment.”

Subsidy-free renewable energy projects set to soar in UK, analysts say

The UK is well on the way to a new era of subsidy-free renewable energy projects that will largely kill off prospects for new gas power stations, according to industry analysts.

The falling cost of wind and solar projects combined with advances in battery storage technology will unlock about £20bn of investment in the UK between now and 2030, Aurora Energy Research said. Onshore wind and solar will both be viable without subsidies by 2025 in the UK, it added.

The prediction comes as the Swedish energy firm Vattenfall announced that it had won a Dutch government tender to develop a windfarm which will become the world’s first without subsidies when built off the Netherlands coast in 2022.

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“The [subsidy-free] future is within reach,” Magnus Hall, Vattenfall’s chief executive, told an industry audience in Oxford.

But the switch to a post-subsidy world would still require some financial aid during the transition period, Hall said, to ensure that risk was fairly shared between energy firms and governments.

Hall urged ministers to consider reversing the UK’s ban on subsidies for onshore windfarms, saying developers of these projects should be allowed to compete in auctions for subsidies.

His call was echoed by two of the UK’s big six energy firms, SSE and ScottishPower.

Alistair Phillips-Davies, chief executive of SSE, said onshore windfarms should be given a chance where communities support them. “I’d like to see onshore wind coming back in the UK,” he said.

Keith Anderson, chief corporate office at Scottish Power, told the Guardian: “Let’s use it, let’s deploy it. There are still areas absolutely where we could build onshore windfarms, areas where the local community are acceptive of windfarms.”

Wind power is expected to account for half of the 18GW of subsidy-free renewables to be built in the UK between now and 2030, according to a new Aurora Energy Research report.

Men installing solar panels

Solar power had largely stalled in the UK after government subsidies were cut in 2015. Photograph: Mike Kemp/Corbis via Getty Images

The other half will be from solar power, which had largely stalled after subsidy cuts in 2015 but received a boost when the UK’s first subsidy-free solar farm opened last year.

Having so much green energy generation will squeeze out the opportunity for the likes of Germany’s RWE to build large gas power stations in the UK.

The government has already downgraded the amount of new gas power capacity it expects to be added by 2030 from 22GW to 7GW, but Aurora said that would shrink to just 1GW if subsidy-free renewables took off as anticipated.

Mateusz Wronski, an analyst at Aurora, said: “The subsidy-free revolution is here and it’s big.”

Prices in the capacity market, the government’s scheme for guaranteeing power supplies during winter, have repeatedly been too low to encourage new large gas power plants to be built.

The energy minister, Claire Perry, announced on Tuesday that the government would be launching a formal review of the capacity market later this year. One consideration will be whether to open up the scheme to renewable energy projects, a step that would further hammer gas.

Perry said the cold snap at the start of March, which saw gas demand jump 40% above normal levels, had shown the UK energy system was robust but there are “lessons to be learned”.

Europe’s advanced biofuels wish – a €25 billion blunder

The Commission’s ‘strategy’ to phase out conventional biofuels in the hope that they will miraculously be replaced by ‘advanced’ biofuels in Europe’s transport energy mix isn’t backed by science or logic, writes Dick Roche.

Dick Roche is a former Irish minister for the environment and a former minister for European affairs. He is currently an advisor to the Hungarian company Pannonia Ethanol.

The EU Commission’s Renewable energy directive RED II proposals are about to be discussed behind closed doors in trilogue in the coming weeks.

A core element in the Commission’s ‘strategy’ is to phase out conventional biofuels in the hope that they will miraculously be replaced by ‘advanced’ biofuels in Europe’s transport energy mix. The proposals are not backed by science or by logic.

They are grossly out of step with what is happening elsewhere in the world. If they are enacted, they will represent one of the biggest blunders the EU has ever made – a blunder with a price tag well in excess of €25 billion.

Remarkably the ‘price tag’ for phasing out conventional biofuels, the investment funding needed to provide Europe with the volume of advanced biofuels envisaged and the vast indirect costs of what the Commission is proposing have, so far, been effectively ignored in the REDII debate.

In 2015 the CEO of Spain’s renewables giant Abengoa warned that the Commission’s dysfunctional policies were turning biofuels into a “zombie industry.” His warning proved to be all too accurate. Abengoa collapsed in Spain’s largest-ever corporate bankruptcy. International banks’ exposure at the time of Abengoa’s collapse was said to stand at over €20 billion.

Abengoa was not the only victim of EU policy shifts. Across the EU, biofuel plants have been ‘mothballed’ or closed down completely.

Investments worth billions have already been written off as a result of EU U-turns on biofuels. The half-billion Euro Vivergo plant, at one point the largest industrial project in England, is a monument to confused biofuel policy.

Turning to the investment needed to realise the Commission’s objectives the EU will require more than 15 billion litres of ‘advanced’ biofuels. Producing that level of second generation biofuels will require a minimum of 150 biorefineries capable of producing 100 million litres per year.

The cost of building a single biorefinery of that scale runs to somewhere between €150-€300 million, suggesting a minimum total bill of more than €25 billion to meet the ambitions implicit in REDII.

Because of the EU Commission’s guerilla war against biofuels since the start of this decade, EU investor confidence in biofuels has been completely undermined.  Banks and institutional investors who have been burned by policy changes are going to be very difficult to re-engage.

The elephant in the room is ‘where is the billions in funding needed to fulfill the REDII pipe dream to come from’?

Some have suggested the EIB might step in. To date, EIB has accounted for less than 0.1% of all capital investments in Europe’s biofuels sector.

A survey released in October last by the German Biofuels Producers [VDB] gives an insight into the rock bottom level of investor confidence in REDII.

Conducted amongst key industry players, the survey found:

  • 81% of the survey participants believe that the reduction in support for conventional biofuels will cause a reduction in investor confidence.
  • 65% of participants did not believe that the Commission proposals would incentivise sufficient investment in biofuel production,
  • All of the respondents believed that the REDII proposals needed to change in order to sufficiently incentivise investment in the sector to meet the advanced biofuel target.

In addition, 54% of the companies surveyed indicated that they were not planning to invest in biofuels, assuming the REDII proposals are transposed into law. None of the companies surveyed had at the time of the survey committed funds to biofuel investment.

A similar survey amongst institutional investors would be very interesting.

The future for ‘advanced biofuels’ has also been raised outside the EU.

The F.O Licht ‘World Ethanol and Biofuel Report’ issued on 19th February concludes its examination of advanced biofuels on a negative note – “so far, the performance of advanced biofuel producers is weak, even on markets with a specific mandate like the United States or other advantageous provision in the biofuels legislation, such as double counting in the EU.”

Against this background, there is no remote possibility that the level of investment needed to scale up to the implicit REDII level will be available in Europe in the foreseeable future.

Without private investment the policy being pushed in REDII will fail: the EU ‘co-legislators’, the Council and the Parliament are being walked into a policy cul-de-sac by the Commission.

The Commission’s impact assessment looks at the cost of the REDII proposals in a manner that can most charitably be described as incoherent.

Ignoring market realities, the Commission assumes, with little corroborating evidence, that advanced biofuels will be cheaper to produce and put on the market than conventional biofuels.

It ignores the prevailing low market price for conventional biofuels and for conventional biofuel feedstock and ignores the reality that there is a major market in Europe for the co-products of conventional biofuels.

It also presumes that the market price for conventional biofuels will rise while the price for advanced biofuels will fall.  Again, there is absolutely no evidence to support that notion.

Another striking weakness in the Commission’s ‘analysis’ is an assumption that existing conventional biofuel refineries can easily be converted to the production of advanced biofuels. This is the equivalent of suggesting that sticking batteries in a clapped-out Volkswagen could avoid the capex needed to transition to electronic cars. The Commission, which has no expertise in the area, has not asked the biofuels industry whether that line of thinking has any merit.

The Commission also suggests that the overall costs of transiting from conventional biofuels could be mitigated by collocating the new bio-refineries on the sites currently occupied by the bio-refineries that the Commission wishes to phase out.  Again there has been no consultation with existing operators and no consideration has been given to the question as to how operators who are being put out of business are to find the hundreds of € millions required to build new facilities.

The question of feedstock raises another matter. The logical place to locate a biofuel facility is as close as possible to its raw materials. Doing so cuts the transport costs and the associated environmental costs of biofuel production. A presumption implicit in the Commission’s views about collocating first and second-generation plants is that feedstock share a common geographical origin. This is at odds with reality.  Again, the Commission has not engaged with the biofuels industry on this aspect of its ‘thinking’.

Finally, the Commission makes the proposition that advanced biofuel facilities are cheaper to build than conventional biofuel refineries. This proposition clashes with reality. Conventional biofuels plants have capital costs ranging from €0.10/litre for simple biodiesel to up to €1/litre for the most sophisticated ethanol plants.

The range is clear and proven over tens of billions of litres of actual capacity.  In contrast, no advanced biofuel plant even comes close to the €1/litre mark, and most are very significantly higher. As a general rule of thumb, 100 million litres of biodiesel capacity costs less than 10% as much to build as 100 million litres of advanced biodiesel capacity.

Another reality that the Commission’s proposition ignores is that over the last decade in Europe, very few of the ‘advanced’ biofuel facilities that have been created have stayed open. There are more closed advanced biofuel plants in the EU than open ones.

In addition to the direct costs of transiting from conventional to ‘advanced’ biofuels, there are other, indirect, cost implications. These have not been properly aired in the debate.

Conventional biofuel production secures annual EU farm incomes of €5-7 billion, has brought very significant investment to rural regions and supports, directly and indirectly, 300,000 jobs.

The potentially devastating impact of removing an income stream worth billions annually to European farm families has been brushed aside in the debate as have the impact of draining this income from the rural communities. The abject failure to fully examine these impacts is perhaps the single most scandalous aspect of the REDII ‘debate’ in the EU Parliament.

The Commission has also made no serious attempt to measure the cost of its proposals in terms of either the number of current jobs that will be axed if REDII is enacted or of the job creation potential that will be lost by ending EU production of conventional biofuels.

The biofuels industry organisation ePure calculated that REDII will bring about the loss of over 100,000 existing jobs, a figure that the Commission has not disputed. It is shameful that the Commission has not been tied down on the jobs issue.

There has also been no attempt to measure the cost of REDII in terms of the rural development potential that will be suppressed by the Commission proposals. This point is particularly important in the case of Central and Eastern EU member states that have a huge unrealised potential to produce highly sustainable, low ILUC, conventional biofuels on land that is currently underutilized.

Across the EU 500,000 hectares of arable land is being abandoned annually as farmers give up farming.  Over the last decade, the major market force that has pushed against this sad reality has been first-generation biofuels.  Getting rid of first-generation biofuels will have huge social and economic implications for rural areas.

Another cost that has been overlooked in the debate is the impact that phasing out conventional biofuels will have on EU animal feed protein.

GMO-free high protein feed is a co-product of conventional biofuel production. Europe is currently heavily dependent on imported animal feed. Over the past decade, 25% of EU feed deficiency was cut by conventional biofuel production. The REDII proposals will reverse the clock making the EU more dependent than ever on GMO based imports.  Ironically the EU Agricultural Commissioner has recently announced a programme that is aimed at addressing the EU protein feed deficiency, a classic example of the silo thinking that reigns in the Commission.

The REDII proposals are a shambles. By any objective standard, the proposals are ill-conceived, flawed and based more on hope than on hard science or on business reality.

The best service that the co-legislators in the upcoming trilogue could do for the citizens of Europe at this point sends the whole sorry mess back to the Commission – or better still put it through the shredder.

A third of power from wind as UK hits new 'green' highs

The amount of wind power generated in Britain reached new record highs on Saturday as the 'mini Beast from the East' swept in, National Grid has confirmed.

The new 'green' record on St Patrick's Day saw onshore and offshore wind turbines generate more than a third of British electricity, as it delivered 14.2 gigawatts of power at 2.30pm in the stormy conditions.

The figure is well above the previous record of 13.9 gigawatts of electricity from wind. It meant that wind power was supplying 34.2 per cent of British electricity at that time, while over the day as a whole the renewable technology accounted for some 35.7 per cent of supplies.

National Grid said the increase in renewable generation posed an 'exciting challenge' for the system operator in balancing supply and demand.

Fintan Slye, director of the system operator at National Grid said: 'We now have significant volumes of renewable energy on the system and as this trend continues, our ability to forecast and manage this is becoming more and more important.

'We have an expert team of forecasters, analysts and engineers who monitor a range of data, to forecast just how much electricity will be needed by consumers and how this is matched by generation available from renewable and other sources.'

He added: '2017 was a record year for green energy and it's looking likely 2018 is set to exceed that. We are excited about the progress being made and looking forward to ensuring it is delivered safely and securely to our customers across Great Britain.'

Wind industry body RenewableUK's executive director Emma Pinchbeck said: 'Yet again, wind is playing a key role in keeping Britain going during a cold spell. When the mini Beast from the East struck on Saturday, over a third of the UK's electricity was being generated by wind.

'We're harnessing a reliable, home-grown source of power which reduces our dependence on imports to maintain the security of our energy supplies.'

Island community hopes to produce almost all of its power through renewable sources

Residents on Canna, part of the Inner Hebrides, will use the money to build a green energy system based around wind, solar and better battery storage.

A small island community hopes to produce almost all of its power through renewable sources after securing £1.3million in funding.

Residents on Canna, part of the Inner Hebrides, will use the money to build a green energy system based around wind, solar and better battery storage.

The island is not connected to the national grid and currently uses three diesel engines to produce power, but it is hoped the renewable sources will provide more than 90% of what is needed when complete.

Canna Renewable Energy and Electrification Ltd (Creel) director Geraldine MacKinnon said: “We’re delighted that construction will soon be underway on our energy project, which has been a long-standing ambition for our community.

“The island is exposed to the full force of Atlantic gales and we can finally start to put that to good use.

“As well as reducing the noise and pollution from the generators the new scheme will give us the capacity to build additional houses here, so that we can increase the number of people who can make their home on this beautiful island.

“We’re very grateful to all of our funders for their support in this vital project.”

Creel will own and operate the new equipment, putting any profits back into the running of the system to help reduce bills for the residents and businesses.

Community Energy Scotland is working with the group to manage the development and construction of the project.

It will use experience from nearby off-grid community schemes on Knoydart and the Isle of Muck.

Canna is thought to have been inhabited since 5000BC, but now supports a small crofting community with 22 residents.

Funding was secured from the Big Lottery Fund, the Scottish Government’s Community and Renewable Energy Scheme, SSE Highland Sustainable Development Fund, Highlands and Islands Enterprise as well as the National Trust for Scotland.

Construction is due to start in April and is scheduled to take around seven months to complete.