Select Committee on Environmental Audit Written Evidence

Memorandum submitted by the Scottish Renewables Forum

  Please find enclosed our views relating to your forthcoming inquiry into "Keeping the Lights on: Nuclear, Renewables, and Climate Change".

  Scottish Renewables is Scotland's leading renewables trade body, representing over 150 organisations and individuals involved in the development of renewable energy projects in Scotland. Our membership ranges from community groups and sole traders, up to major Scottish utilities and international plcs. Between them they are active in the development of biomass, hydro, solar, wave, wind and tidal energy projects. Further information about our work and our membership can be found on our website.

  The Environmental Audit Committee's inquiry comes at a crucial time in reviewing the UK's capacity for electricity generation, transmission and the impact on reducing carbon dioxide emissions. Our submission provides evidence and opinion in support of the role of renewables within this debate and aims to highlight the implications of government policy at both UK and Scottish levels. This submission is complementary to the evidence submitted to the Scottish Affairs Committee inquiry into Meeting Scotland's Future Energy Needs (HC 259-I, 23 March 2005).

  The key points which Scottish Renewables will make are:

    1.  Renewable energy is delivering and proving its worth to UK energy supplies. The UK's plans to encourage further development of renewable schemes has led to a rapid upscaling of project development. This trend is particularly strong in Scotland where significant resource is located. However, if this initial work is to be realised and result in achievement of renewable targets, then government and parliament must ensure continued confidence in the ability of government to support delivery, by not altering the fundamentals of the market.

    2.  The key issue facing UK is how to consider the replacement of current conventional generation that will complement the planned renewable target (20% of the UK market, and 40% of the Scottish market by 2020); ie the issue is how to achieve the non-renewable mix. The debate is not, therefore, about renewables vs. conventional as both will be needed.

    3.  If renewable energy in the UK is to be successful there must be co-ordination across Government departments and with government agencies. Too often our industry must deal with conflicting policies and regulations.

    4.  The costs of generating electricity in Scotland is being disadvantaged under the creation of the UK electricity market due to high transmissions costs, thus unfairly increasing the costs of renewable-sourced electricity within the UK.

    5.  In considering a future appropriate energy mix, the issue of non-electrical sources is often forgotten. Renewables also has a role in helping to meet the UK's future heating and transport energy needs.

    6.  Renewable energy, of all generating technologies, contributes the least to carbon dioxide emissions and will assist the UK in meeting its targets in emissions reduction with minimum concern over waste disposal.

    7.  Renewable energy sources provide a strategic fit with the UK Govt's aims on security of supply.

    8.  Increased investment in renewables development can assist the UK's exporting potential for both electricity supply and the manufacture of renewables technology, eg the Pelamis project in leading the marine energy sector. In this regard, prioritisation of renewable development will maximise future economic export opportunities.

  The following information provides detail on each of these key points.


  The UK Government has set a target that 10% of its electricity comes from renewable sources by 2010. Beyond this is a 15% target for 2015 and an aspiration that the 2010 target is doubled by 2020.

  Within Scotland we have higher targets. For 2010 there is an 18% target and a 40% target for 2020. These targets reflect Scotland's substantial renewable resource and aspirations for associated economic development, and also recognise that Scotland will make a sizeable contribution to UK targets.

  Currently approximately 14% of Scotland's electricity comes from renewable sources. The bulk of this is hydro, but wind and landfill gas also make contributions. There are also sufficient wind energy projects now under construction or with a resolution to consent from determining authorities to ensure that Scotland meets its 18% target. Achievement of this Scottish target will be important to ensure that Scotland can make a strong contribution to the GB's electricity target.

  Looking at Scotland's 2020 target it should be noted that all renewable technologies will need to play their part here. We would envisage that this target will be met as follows:

    —  ¼ hydro (ie 10%)[364]

    —  ½ wind (ie 20%)

    —  ¼ emerging technologies (ie 10%) = biomass, tidal and wave energy

  These targets are not to be interpreted as ceilings on each energy source. It is worth noting that there is currently a substantial amount of wind energy in the Scottish planning system now. We would not expect all of these projects to come to fruition either because of planning or grid constraints. There have been calls on the Scottish Executive to develop a National Strategic Plan for wind or even to impose a moratorium on project proposals. We would caution against this.

  The Scottish Executive's Forum for Renewable Energy Development in Scotland (FREDS) has recently provided guidance for communities, planners and developers in Scotland[365]. However, the Scottish Executive still needs to provide better guidance on "cumulative impact"[366] to assist planning authorities with multiple applications for development in a particular locality. Hopefully, the Environmental Advisory Forum on Renewable Energy set up the Deputy Scottish Minister for Enterprise, will meet this need.

  To ensure that other renewable technologies can play their part in meeting future energy needs the UK Government—in partnership with the devolved administrations—needs to ensure the following:

    (a)  Marine energy is given a positive financial and planning framework to develop in. This will provide incentive to technology and project developers to move forwards in developing first generation projects.

    (b)  Appropriate support mechanisms for biomass energy are developed, including development of a heating target (see later). It should be noted here that previous UK Government support on biomass has not been usable in Scotland because it has focused on energy crop support instead of support for forestry diversification. This discrepancy has now been resolved.

    (c)  Encouragement of micro-generation—including ensuring support in planning and building regulations and providing incentives to electricity supply companies to facilitate cost effective connection and allow the sale of electricity from household or small business sources. The current system frustrates connection of micro-generation through being costly and bureaucratic. We are hopeful that the Department of Trade and Industry's recent consultation on microgeneration will assist in resolving some of these matters.

  It is also worth noting that there is much discussion about the need for grid upgrades and new infrastructure as a result of new renewable energy proposals. New generation of any kind does need new infrastructure. However, much of the upgrade plans for new infrastructure is to modernise old infrastructure up to 50 years old and the costs shared with those wishing to utilise it for generation. Infrastructure upgrades are essential for both security of supply to growing cities (such as Inverness) and to enable new generating sources to supply the National Grid.

  Another issue also needing to be considered is the issue of intermittency and the effect that a high penetration of renewables will have on the whole electricity system. Wind and wave energy generate variable levels of power dependent on weather conditions. Tidal energy is a predictable but not constant source and varies across the day and seasonally.

  However, at the levels of penetration of these technologies expected by industry experts express confidence that "intermittency" can easily be managed. Indeed, such a problem is an insignificant one when compared to the daily challenge of managing the constant rise and fall of electricity demand. The GB System Operator National Grid Transco has stated that:

    based on recent analysis of the incidence and variation of wind speed we have found that the expected intermittency of wind does not pose such a major problem for stability and we are confident that this can be adequately managed . . . [367]

  Furthermore, the Carbon Trust in its "Renewable Network Impacts Study" of 2004 stated that:

    At the current target levels, intermittency is not a significant issue affecting the development of renewable generation[368].


  A key question facing the UK Government is how it plans to replace existing conventional generation with new generation. With renewables set a target of increasing its contribution from 10% to 20% some of this will be replaced. However, there will still need to be some new conventional plant.

  There has been much play in the media about the choice between renewables and nuclear and how they can help to meet UK climate change obligations. However, it is the Scottish Renewables' view that there is no policy choice here, and choosing renewables does not necessarily mean rejecting nuclear. We would reject this argument because renewable energy is worthwhile on its own terms as a viable energy source. Similarly the case against nuclear does not stand or fall because of the strength or weakness of the renewables argument.

  The wider challenge for the UK is therefore how to replace existing conventional generation. Put simply there needs to be a debate on what a future 80% of conventional generation will look like and what further contributions renewables can make.

  Scottish Renewables would therefore urge the Inquiry to help move the debate forward: it should not be about the 20% vs 80% but how best to provide for a future 80% of UK's electricity needs. New build and replacement will be needed here. As with renewables, we see that conventional generation works best when there is a mix, because this means that the strengths and weaknesses of each technology can be balanced.

  As for the interplay between conventional and renewable and generation and demand we would note the importance of a mixture to ensure that stability of supply is maintained. Key here is having future thermal plant that can be turned up or down to reflect (a) changes in demand, and (b) changes in contribution from more intermittent sources. Clean coal and gas are best placed to provide such thermal plant, but both pump storage of hydro and biomass can also play a role.

  Nuclear energy provides baseload power but cannot be turned up or down easily. However, this fact can be balanced by the continued use of pump storage and demand side management tools such as use of white-goods metering.


  It is noteworthy that a continued frustration of ours is how regulation of the electricity market can often work against achievement of policy objectives in electricity. While there are different roles for policy and regulation, there would seem to be scope for a degree of rationalisation.

  Our key concern is the implementation of the British Electricity Trading & Transmission Arrangements that has seen the Scottish electricity market and the English-Welsh market merge. While this provides a larger market for generation, the current system will retain a number of regulatory differences. For example, transmission is classified differently in Scotland, so more renewable generators will be exposed to transmission charges than in England and Wales. Also the level of charges in Scotland is substantially higher.

  We estimate that of the total £290 million charging bill payable by generators, £140 million will be met by Scottish generation, despite making up only 13% of total GB generation. This means that the average Scottish charge is six times higher than the average English-Welsh charge. Such a result penalises all forms of generation and ignores the fact that the development opportunity is often greater (primarily due to better resources or more site locations).


  Electricity use makes up approximately 20% of our total energy use. Heating makes up approximately 40% and transport fuel approximately 40%. Given concerns about future costs of gas as we become more dependent on imports, alongside concerns about oil price rises, it would therefore make sense to consider likely impacts of these changes on the cost of future heating and transport needs, and whether there will be an economic impact to the UK because of this.

  Renewable energy can provide energy for heating and transport. For example biomass and solar energy can help provide heating energy (biomass works best in combined heat and power applications where heat and electricity are generated). Biofuels and wastes can be used to make bio-ethanol and bio-diesel to mix with or replace petrol or diesel. Longer term renewable electricity projects could be used to aid hydrogen production for use in fuel cells.

  Thus while most of the policy debate is focussed on electricity needs, we are fast approaching the time when long-term changes will be required in how we meet heating needs. Consideration of meeting energy for future transport needs is not too far behind this. We would therefore urge your Inquiry to consider in more detail how these issues should be be considered and resolved by the UK Government.

  I hope that the above information is of assistance to you in your inquiry. If you would like further information, or would wish us to present our views to the Inquiry itself, we would welcome the chance to assist you further.

21 September 2005

364   While hydro currently provides approx 11% of Scottish electricity needs, we would expect this contribution to fall as rising electricity demand will not be offset by new generation. Thus while the level of hydro generation will increase over time, its percentage contribution may fall. We have estimated this at 10% for simplicity. Back

365   FREDS Future Generation Sub Group (June 2005) Scotland's Renewable Energy Potential: Realising the 2020 Target. Back

366   Cumulative impact primarily affects wind energy proposals but can be applied to a mix of technologies or development types in a particular locality. Back

367   National Grid UK, 2004. Seven Year Statement. Back

368   Carbon Trust, 2004, The Carbon Trust and DTI Renewables Network Study. Back

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