|
Memorandum submitted by EDF Energy (ACC11)
Environmental Audit Inquiry - Adapting to climate change
1 EDF
Energy is one of the
EDF Energy - Key points
· EDF Energy supports the Governments actions to mitigate Climate Change, and also recognises the need for adaptation measures as our understanding of the unavoidable impacts of climate change becomes more certain.
· The Power Sector already carries out significant reporting under current regulations and provides significant information on the sector under the Government's established reporting regimes. There needs to be compelling arguments to justify the provision of additional information.
· EDF Energy believes it would be more appropriate to review the adaptation strategy for electricity supply at a sectoral level rather than targeting individual operators.
(II) EDF Energy input to the EAC inquiry on Climate Change Adaptation
Background
2 We are pleased to see
Government taking an active role in adapting to climate change. We present here
some views on Climate Change Adaptation as they appear to an operator of large
infrastructure assets and networks within the
On Adaptation Reporting
3 The power sector already undertakes significant reporting under current regulations and provides significant information on the sector under the Government's established reporting regimes. This includes being Category 2 responders under the Civil Contingencies Act 2004, membership of the Energy Emergency Executive Committee (E3C) and the Critical Infrastructure Resilience Programme (CIRP). There needs to be compelling arguments to justify the provision of additional information.
4 Climate change adaptation is a much broader issue than mitigation and affects a much wider and more diverse stakeholder group. This of course necessitates the involvement of a number of Government departments in order to best represent the interests of these stakeholder groups. While gathering views from all groups is important, it should be recognised that some organisations will be engaged in a variety of forums and care should be taken to avoid duplication of reporting efforts.
5 Industry regularly provides information to a wide range of Government departments on climate change related issues and environmental issues. A cohesive approach is required from these departments to ensure that this information is collated and used in the best possible way.
6 We believe it would be more appropriate to review the adaptation strategy for electricity supply at a sectoral level rather than targeting individual operators, given the national strategic importance of electricity infrastructure. This would also make best use of existing reporting arrangements and avoid an unnecessary additional administrative burden on operators.
7 In the
case of the
8 Should Government wish to include the power sector within the Adaptation Reporting power initiative then we believe the following key points should be considered:
· EDF Energy already carries out a wide range of activities in relation to climate change;
· It is necessary for Government to define a clear objective of the reporting power, one that genuinely adds value to the reporting needs in respect of climate change issues;
· EDF Energy supports a phased approach to the introduction of the adaptation reporting power with major new infrastructure reporting first;
· EDF Energy believes that any reporting should be on a sectoral basis in the first instance;
· Any reporting carried out should reflect the level of detail that can be provided on the impacts of climate change, and at this stage we believe that this should be relatively 'light touch'.
· We believe that the reporting authorities will need a harmonised approach to reporting for the adaptation reports to be of benefit to Government. We believe that the Guidance needs to be reviewed to reflect this; and
· Government needs to manage expectations around what can be delivered as experience with climate change mitigation shows that it takes time for requisite skills development and capacity building.
On the Adapting to Climate Change Programme
9 EDF Energy agrees with the statements made in Governments "Adapting to Climate Change in England" report and in the Stern report that Government's role in relation to Climate Change Adaptation should be one of facilitation. This should involve ensuring that adequate resources and information are available to organisations to allow them to make informed decisions regarding the protection of their assets.
10 We do not believe that it is appropriate for each Devolved Administration to be producing a separate Adaptation programme. As an organisation operating assets within different administrations we are concerned about contradictory regulation. This is an area in which common approaches to reporting and adaptation need to be developed.
11 We agree with the Government's observation within the Adapting to Climate Change Programme that a different approach will be required for large long-lived new infrastructure. That is why we propose that any reporting on this infrastructure is carried out in line with the current planning process.
12 Organisations operating large infrastructure assets have it in their own interest to protect these assets. Therefore they should be allowed to proceed with their own activities to protect the assets with support from Government.
13 EDF Energy has been involved in a number of initiatives to understand the impact of climate change on our assets. EDF Energy, along with National Grid and E.On UK, worked with the Met Office in 2006 to produce a scoping study on the impacts of climate change on the UK electricity industry and, as a part of a broader group of participants, has also commissioned a further study, "Impact of Climate Change on the UK Energy Industry", to develop practical responses to Climate Change.
14 Additionally our subsidiary
that operates our nuclear plant in the
a. A report from the Met Office summarises the kinds of effects that may be expected at each of our power station sites (temperature, precipitation, wind and coastal factors)[1] b. Two reports for the public that outline the potential impacts of climate change that British Energy faces at our sites[2] and a note to inform the public of impacts of climate change on replacement nuclear build[3]. These reports provide confirmation that we are currently operating our plants in the safest possible manner.
15 We also support the Government's observations on the development of skills and resources to deal with Climate Change Adaptation. As noted earlier the development of these skills across the economy will take some time and Government needs to manage these expectations.
5 October 2009
[1] http://www.british-energy.com/pagetemplate.php?pid=354 [2] http://www.british-energy.com/documents/Climate_Change_and_replacement_nuclear_build.pdf [3] http://www.british-energy.com/documents/Climate_Change_and_replacement_nuclear_build.pdf |