Select Committee on Scottish Affairs Written Evidence


Letter to the Committee from Confederation of UK Coal Producers


  The Confederation of UK Coal Producers (CoalPro) represents member companies who produce over 90% of UK coal output. I understand that the Scottish Affairs Committee welcomes written evidence on, amongst other issues, how the shortfall in energy output can be met once nuclear power no longer provides Scotland's energy needs.

  CoalPro assumes from the above that the Committee has concerns about the provision of adequate electricity supplies in Scotland following the closure of the Hunterston and Torness nuclear power stations which is expected to take place before 2020.

  However, CoalPro believes that these concerns are likely to underestimate the extent of the problem as, under the Large Combustion Plants Directive (LCPD), decisions taken by Scottish Power are likely to also lead to the closure of both of Scotland's coal-fired plants, Longannet and Cockenzie, by 2015.

  The LCPD requires operators of coal-fired power plants to meet stringent emission limits for sulphur dioxide (SO2), oxides of nitrogen (NOx) and dust from 1 January 2008 onwards. Operators can "opt out" of the Directive in respect of any individual power station, in which case the operation of individual generating units will be limited to a total of 20,000 hours (less than 2½ years of continuous running) after which they will have to close. Closure is required in any event by the end of 2015. In addition to these operating restrictions, plants would still have to meet emission limits under the IPPC regime.

  Scottish Power have chosen to opt out both the Longannet and Cockenzie power stations under the LCPD. Whilst they have up until 30 June 2005 to reverse this decision, it is considered unlikely that they will do so. This means that both these power stations will have to close by the end of 2015 and that each unit thereat can only operate for a total of 20,000 hours between 2008 and 2015.

  The position could yet be worse. If, having used up a proportion of the 20,000 hours, any of the units at either of these stations requires major expense, then the question will inevitably arise as to whether such expense would represent a viable proposition in the light of the remaining available operating hours. Premature closure of some, or all, of the generating units at the stations is therefore entirely possible.

  The overall impact, therefore, is that at some time between 2010 and 2020, the great majority of Scotland's electricity generating capacity will close. The remaining capacity will comprise hydro and renewables, the gas-fired power station at Peterhead and certain CHP installations.

  The Scottish Executive has an objective of generating 40% of its electricity from renewable sources by 2020. Even if this ambitious objective is achieved, renewable generation is intermittent and cannot be relied upon to supply electricity when required at times of peak load. Such a level of renewable generation capacity would need to be supplemented by generating plant capable of rapid load following for peak loads, and constantly by "spinning reserve".

  The gas-fired plant at Peterhead might be able to provide some of this back up, but is far from ideally suited to doing so. CCGTs were not designed to ramp up and down rapidly and lose considerable efficiency when required to do so. In any event, the capacity of this station would be fully required in winter periods.

  Scotland would therefore have to rely at times of higher electricity demand, and more generally for spinning reserve, on imports of electricity across the interconnector from England, and specifically from the remaining English coal-fired power stations (ie those that have not opted out of the LCPD). The question must arise as to whether the capacity of the interconnector would be adequate in all circumstances.

  Assuming that hydro/renewables generation cannot be higher than 40% by 2020, are there any other alternatives? Only new build, nuclear, gas or coal, would appear to be a feasible alternative, and perhaps only new build coal could provide the operating flexibility required.

  I cannot comment on the likelihood of new nuclear build, but it is apparent that nuclear stations cannot operate flexibility. New gas-fired capacity may be capable of being designed to do so, but gas prices have been raising rapidly and North Sea gas production from the UK sector is now in decline. The gas would therefore have to be imported.

  Fortunately, all may not be lost with respect to coal-fired generation in Scotland. First, it is unlikely, but not inconceivable, that Scottish Power may decide to fit flue gas desulphurisation at Longannet. This would enable that station to opt back in again by 30 June 2005.

  Secondly, it is known that Scottish Power have been in discussion with Mitsui-Babcock about advanced coal generation technology in relation to Longannet. If such technology were to be installed there, it would enable the station, which is relatively modern, to meet the requirements of the LCPD with respect to new plant, and therefore to continue beyond 2015.

  It may be that the Committee will wish to seek a submission from Scottish Power with respect to both of the above.

  CoalPro is pleased to be able to submit written evidence as set out in this letter and remains willing to provide any further information that may be required.

David Brewer

Director General

6 January 2005

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