Memorandum 33
Submission from the Environment Agency
1. INTRODUCTION
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. ENVIRONMENTAL
IMPACTS
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. NEED FOR
COST-EFFECTIVE
SOLUTIONS
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. BIOMASS
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. TIDAL POWER
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. ENERGY STORAGE
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. ENERGY FROM
WASTE
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. CONCLUSIONS
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 http://www.ofgem.gov.uk/Sustainability/Environmnt/Policy/Documents1/16669-ROrespJan.pdf Back
51
Synthesis of Climate Change Policy Evaluations, DEFRA 2006 http://www.defra.gov.uk/environment/climatechange/uk/ukccp/pdf/synthesisccpolicy-evaluations.pdf Back
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