Select Committee on Innovation, Universities, Science and Skills Written Evidence

Memorandum 33

Submission from the Environment Agency


  1.1  The Environment Agency welcomes the opportunity to submit evidence to the inquiry of the Select Committee on Science and Technology into renewable energy generation technologies.

  1.2  The Environment Agency recognises renewable energy as a key component of the carbon-constrained 21st Century energy economy. However, carbon saving objectives must not be allowed to automatically override other environmental concerns.


  2.1  No energy source is completely harmless to the environment. For each technology, there is a trade-off between the wider benefits (eg in terms of energy security and lower CO2 emissions) and their social and more local environmental impacts. The key issue for the Environment Agency is to ensure that all environmental implications are fully taken into account in the deployment of renewable energy resources, so that the most sustainable option is selected.

  2.2  In order to allow informed choices about the most sustainable option, it is essential that the renewable research and development agenda includes social and environmental issues, in addition to engineering aspects. The case of onshore wind demonstrates how social rather than engineering factors can be the dominant factor in determining the level of deployment (or lack thereof) of a technology.

  2.3  Life-cycle analysis is a useful tool for calculating cradle-to-grave environmental impacts. While whole life impacts are reasonably well known for some renewable technologies (eg on-shore wind), there are research gaps for other technologies (eg tidal technologies) which need to be addressed.

  2.4  In addition, a clear assessment framework for determining the carbon footprint of different renewable technologies is needed. It should not be assumed that renewable technologies automatically provide carbon savings. We are particularly concerned that some biofuels appear to have a larger carbon footprint than some fossil fuels.


  3.1  In addition, questions need to be asked whether renewables, in particular under the current support system (the Renewables Obligation, RO) are the most cost-effective way to achieve carbon savings. A recent assessment by Ofgem suggests average emission reduction costs under the RO of £400 t/C, compared to £66 t/C for reductions under the European Emission Trading system. Under the Energy Efficiency Commitment (EEC) each tonne of carbon emissions reduced results in savings of up to £60, depending on the measure applied.[50] Analysis of the UK Climate Change Programme found that while some measures such as the EEC produce a net benefit (thus providing a real "win-win" solution), the RO has a net cost.[51]

  3.2  In view of the large CO2 reduction effort needed to achieve the UK's targets, it is important that emission reductions are achieved in the most cost-effective manner, while at the same time minimising environmental impacts. For this reason, energy efficiency measures should be prioritised. Renewable energy resources would be more effective if the energy they supply was used in efficient applications. While we recognise that some renewable technologies need extra support to allow commercialisation, there needs to be a coherent support system that aims at leveraging the most cost-effective carbon solutions, with some additional support towards technologies further from commercialisation.

  3.3  We focus the remainder of our comments on renewable sources particularly relevant to the Environment Agency's role as environmental regulator—biomass, tidal energy, energy storage and energy from waste. These renewable sources are of specific concern in terms of their potential environmental impacts.


  4.1  We support bioenergy as a renewable source of energy. However, adequate safeguards must be in place to minimise environmental impacts which can include:

    —    large-scale changes to land use for energy crops;

    —    effects on water resources, soils and biodiversity;

    —    the handling and reuse of wastes as fuel; and

    —    emissions from power stations.

  4.2  Whole life-cycle impacts of bioenergy should be assessed including net greenhouse gas emissions (including the emissions related to inputs such as fertilisers), environmental and biodiversity impacts and wider sustainable development contributions. Water consumption of certain bioenergy crops is an important concern if grown in low rainfall parts of the country, such as East Anglia and the South East.

  4.3  Incentives such as grants, reduced excise duties or supplier obligations should be focused on those technologies and fuels with the lowest environmental impact.

  4.4  Provided other environmental issues are addressed, we welcome fuels that reduce the overall emissions of CO2 in the short to medium term. Clean, treated wastes of biological origin could be used as part of local energy solutions.


  5.1  England and Wales have a large part of Europe's tidal resource. Tidal power could play an important role in reaching renewable energy targets. Yet, environmental impacts could be substantial as our estuaries are of international importance for fish and migratory birds.

  5.2  Government should take a strategic overview of the development of the tidal energy resource, to ensure climate change obligations are balanced with other environmental obligations. An ad-hoc, case-by-case approach by individual developers is unlikely to deliver the most sustainable solution overall.

  5.3  We have concerns about the renewed interest in the Severn Tidal Power Barrage, which in our view would cause irreversible impacts to the internationally important habitats and ecology of the estuary. We cannot envisage how required compensation measures could be provided. We also have wider concerns relating to its implications for a number of other environmental considerations, such as water quality, water resources and flood risk management. We thus welcome that the Sustainable Development Commission is carrying out a major study into the Severn Barrage. The study is due to be published by September 07 and we hope that the Committee will be able to consider this in its deliberations.

  5.4  Other tidal energy options such as tidal stream turbines or tidal lagoons need to be explored and their environmental impacts assessed more fully.


  6.1  Energy storage is crucial to the success of renewables, many of which are intermittent. However, storage has its own environmental implications, especially in the case of batteries most of which contain heavy metals (eg lead, Cadmium). Unless these batteries are recycled or carefully disposed off, they can add to soil and water pollution. In the Environment Agency's view, more research is needed into alternative battery technologies, in particular for large scale applications.


  7.1  We recognise that a large proportion of the waste stream is made up of material from renewable resources, such as food wastes and paper. However, as recycling reduces greenhouse emissions more than any other waste treatment activity and generally has lower overall environmental impacts, we believe that it should be given priority. After recycling, energy from waste can play a role provided air pollution standards are met.


  8.1  The Environment Agency supports the acceleration of renewable energy research, development and deployment as a pillar of the UK's climate change policy. However, we believe that greater attention needs to be paid to carbon footprints and other environmental impacts of renewable technologies to ensure that they are truly sustainable.

July 2007

50   Reform of the Renewables Obligation 2006: Ofgem's response Back

51   Synthesis of Climate Change Policy Evaluations, DEFRA 2006 Back

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